NEW YORK -- Most apparel was spared from Section 301 tariffs until September, when a large swath of imports was hit with 15 percent additional tariffs, though a few categories were on List 3, and are facing an additional 25 percent. Between the two rounds, 77 percent of apparel is subject to 301 tariffs. The Office of the U.S. Trade Representative is now tasked with considering exclusion requests for List 3, and Assistant USTR for Textiles Bill Jackson said that volume is “astounding" -- about 30,000 requests. Only 600 of those are in tariff code chapters 50 to 60, he said, and fewer than 20 have been granted approval so far.
NEW YORK -- Companies hoping to avoid Section 301 tariffs by a shift in origin should research CBP rulings first, United States Fashion Industry Association customs counsel John Pellegrini said. And if the product they are importing is even a little different from what's in a ruling, ask for a new ruling. "It's a time to play conservative," said Pellegrini, who was speaking at the Nov. 7 USFIA Trade and Transportation conference.
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The International Trade Commission issued Revision 16 to the Harmonized Tariff Schedule. Changes in the new edition that take effect Nov. 1 include the restoration of eligibility of many Ukrainian goods for the Generalized System of Preferences, as well as implementation of the results of the Office of the U.S. Trade Representative’s 2019 GSP product review, which also requires minor changes to tariff subheadings for certain plywood. A new set of exclusions from Section 301 tariffs on products from China are also added to the tariff schedule.
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CBP's role in considering Section 301 exclusion requests is limited to a review of drafted exclusions from the Office of the U.S. Trade Representative, a CBP spokesperson said. Asked whether CBP sees the full exclusion requests in their entirety, the spokesperson said "CBP does not review individual petitions for exclusions to the remedy." USTR "evaluates and approves requests for exclusions to the China 301 remedy," the CBP spokesperson said.
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