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.
International Trade Today is providing readers with some of the top stories for Oct. 28 - Nov. 1 in case they were missed.
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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The International Trade Commission in recent days posted Revision 11 to the 2019 Harmonized Tariff Schedule. All changes relate to implementation of the first group of exclusions from tranche three of Section 301 tariffs on products from China (see 1908050010). That includes the creation of new tariff subheading 9903.88.13 for products filed under the new exclusions.