CBP created Harmonized System Update (HSU) 1913 on July 21, containing 113 Automated Broker Interface records and 23 Harmonized Tariff Schedule record, it said in a CSMS message. The update includes adjustments required by the Office of the U.S. Trade Representative's announcement of new exemptions from Section 301 tariffs on China (see 1907080008). Modifications required by the verification of the 2019 HTS are included as well.
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CBP will add the ability in ACE for importers to file entries with the sixth group of exclusions from the first tranche of Section 301 tariffs on July 11, it said in a CSMS message. Filers of imported products that were granted an exclusion (see 1907080023) should report the regular Chapter 84, 85 or 90 Harmonized Tariff Schedule number, as well as subheading 9903.88.11, 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 9903.88.11 is submitted,” CBP said.
The Office of the U.S. Trade Representative is publishing its latest list of product exclusions from the first tranche of $34 billion in Section 301 tariffs on China (see 1907080008). This sixth list of exclusions includes 110 subsets of tariff numbers in chapters 84, 85 and 90. The new exclusions take effect retroactively from July 6, 2018, when the $34 billion in tariffs originally entered into force, and will remain for one year following publication of USTR’s notice. USTR is creating Harmonized Tariff Schedule subheading 9903.88.11 for the new set of exclusions.
The Office of the U.S. Trade Representative issued a sixth list of product exclusions from Section 301 tariffs on goods from China. Newly exempt from the tariffs are "110 specially prepared product descriptions," the agency said. The exclusions cover 362 separate requests, according to the notice, which is scheduled for publication in the July 9 Federal Register. The product exclusions apply retroactively to July 6, 2018, the date the first set of tariffs took effect, and will remain in effect until one year after the notice is published.
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:
The rapid changes in trade policy have elevated the need for adroit trade compliance management at international companies that hadn't previously been so concerned with customs duties, said two compliance professionals who spoke at the American Association of Exporters and Importers Annual Conference in Washington on June 28. "It's been an overall breaking down walls of communication" among the various groups at the company who "historically" didn't interact very often, said Antoinette Montoya, corporate export-import compliance manager at Bechtel Corporation. Now, though, "we've had a lot of really good strategic relationships built out of this," she said. Whatever happens with subsequent administrations, those relationships will "really help us in the long run," Montoya said.
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CBP's Office of Regulations and Rulings is facing a massive increase in ruling requests involving products from China, in addition to its need to weigh in on exclusion requests, CBP Assistant Commissioner Brenda Smith said June 28 at the American Association of Exporters and Importers Annual Conference in Washington. The trade remedy exclusion requests are reviewed by OR&R "because of the tariff classification inherent in the application and then in the final determination," she said. Exclusion requests for the Section 232 tariffs on steel and aluminum are now at about 80,000, well above the 10,000 that were expected when first announced, she said. That's not counting the exclusion request processes now available for the first three tranches of Section 301 tariffs on goods from China, she said.
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