2019 is shaping up to be another active year in terms of changes to the Harmonized Tariff Schedule. Like last year, a series of revisions were necessary in the first half of the year to implement Section 301 exemptions and an increase for $200 billion worth of the China tariffs from 10 percent to 25 percent. Other major changes are related to the Generalized System of Preferences, and in particular the removal of India and Turkey from the program. In all, seven revisions were issued prior to the mid-year Revision 8, as follows:
Harmonized Tariff Schedule
The Harmonized Tariff Schedule (HTS) provide classification provisions and duty rates for almost every item that exists. It is a system of classifying and taxing all goods imported into the United States. The HTS is based on the international Harmonized System, which is a global standard for naming and describing trade products, and consists of a hierarchical structure that assigns a specific code and rate to each type of merchandise for duty, quota, and statistical purposes. The HTS was made effective on January 1, 1989, replacing the former Tariff Schedules of the United States. It is maintained by the U.S. International Trade Commission, but CBP is responsible for interpreting and enforcing the HTS.
The final set of tariff reductions under the Expanded World Trade Organization Information Technology Agreement will take effect July 1. International Trade Today is again providing a table of changes to tariffs in the Harmonized Tariff Schedule for certain products as a result of this last round of implementation. While tariffs on many products were eliminated completely when the agreement took effect in July 2016, other products subject to the expanded ITA have seen tariffs phased out over a three-year period, with tariffs for all remaining products covered by the agreement now reduced to zero in 2019.
The International Trade Commission on July 1 posted Revision 8 to the 2019 Harmonized Tariff Schedule. The semiannual update to the HTS implements the fourth and final round of tariff cuts under the expanded World Trade Organization Information Technology Agreement. It also extensively reorganizes 10-digit tariff subheadings covering aluminum products, and adds tariff provisions for aerial work platform trucks, frozen berry mixes, diamond grinding wheels, storage lockers and certain electric motorcycles.
The International Trade Commission posted Revision 8 to the 2019 Harmonized Tariff Schedule. The semiannual update to the HTS implements the fourth and final round of tariff cuts under the expanded World Trade Organization Information Technology Agreement. It also extensively reorganizes 10-digit tariff subheadings covering aluminum products, and adds tariff provisions for aerial work platform trucks, frozen berry mixes, diamond grinding wheels, storage lockers and certain electric motorcycles.
While the reasons that Section 301 tariff exclusions were granted are murky to trade lawyers, in general, more information is better when submitting requests, trade lawyers said during a panel at the American Association of Exporters and Importers Annual Conference June 28. Pictures of your product, emails from domestic companies saying they can't provide the quantity you're looking for, and the number of U.S. jobs that are imperiled if you have to pay 25 percent more for this product are all good pieces of information to provide, they said.
The final set of tariff reductions under the Expanded World Trade Organization Information Technology Agreement will take effect July 1. International Trade Today is again providing a table of changes to tariffs in the Harmonized Tariff Schedule for certain products as a result of this last round of implementation. While tariffs on many products were eliminated completely when the agreement took effect in July 2016, other products subject to expanded ITA have seen tariffs phased out over a three-year period, with tariffs for all remaining products covered by the agreement now reduced to zero in 2019.
The Consumer Technology Association “urges the administration to quickly implement a broader and more effective exclusion process for List 4” than it did for lists 1 and 2, it said in comments posted in docket USTR-2019-0004. “Unlike the product exclusion process for the first two tranches of tariffs,” which required applicants to submit requests by a hard deadline, “circumstances warrant” installing a process for List 4 that works “on a rolling basis,” it said.
The International Trade Commission issued Revision 7 to the Harmonized Tariff Schedule. The revised tariff schedule now reflects the removal of India from the Generalized System of Preferences program (see 1905310072), with the country removed from lists of GSP beneficiaries in General Note 4, and a bevy of subheadings for India removed from the list of country-product pairs ineligible for GSP because they exceeded Competitive Need Limitations. The new version also ends an exemption for India from Section 201 safeguards on solar cells and washing machines, because India is no longer considered a developing country that qualifies for the exemption. These changes took effect June 5.
CBP will add the ability in ACE for importers to file entries with the fifth group of exclusions from the first tranche of Section 301 tariffs on June 11, it said in a CSMS message. Filers of imported products that were granted an exclusion (see 1906030038) should report the regular Chapter 84, 85 or 90 Harmonized Tariff Schedule number, as well as subheading 9903.88.10, for products subject to Section 301 duties on products from China but that have been granted an exclusion by the Office of the U.S. Trade Representative. “Importers shall not submit the corresponding Chapter 99 HTS number for the Section 301 duties when HTS 9903.88.10 is submitted,” CBP said.
The International Trade Commission recently issued Revision 6 to the Harmonized Tariff Schedule. Changes include the removal of Turkey from the Generalized System of Preferences program (see 1905170004), including its elimination from the list of GSP countries in General Note 4 and the removal of Turkish goods from the list of country-product pairs ineligible for GSP. The new version also removes Turkey from the lists in U.S. Notes 17 and 18 to Chapter 99 of developing countries exempt from safeguard duties on washing machines and solar cells. These changes took effect May 17. Effective May 20, the tariff schedule is amended to remove additional Section 232 tariffs on steel products from Turkey provided for in U.S. Note 16 to Chapter 99 and in subheading 9903.80.02, so that Turkey is now subject to the 25% tariff applicable to most other countries. Finally, Revision 6 includes changes to reflect the recently announced exemption of Mexico and Canada from Section 232 tariffs on steel and aluminum (see 1905170044), with modifications to U.S. Note 16 to Chapter 99 and subheadings 9903.80.01 and 9903.85.01 that took effect May 20.