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Tariff Update

January 4, 2019:

Earlier this week, Customs and Border Protection (CBP) posted a notice on Section 301 Product Exclusions (announced on December 28, 2018).  The notice provided the following guidance regarding exclusions granted by USTR:

  • On December 28, 2018, the U.S. Trade Representative published announced the decision to grant certain exclusion requests from the July 2018 list of goods subject to a new 25% duty.  The product exclusions announced in this notice will extend for one year after the publication of this notice.
  • This exclusion applies to injection molds and mold bases used in the plastics and rubber industries.  These molds are covered by HTS code 8480.71.8045.
  • The exclusions can be applied retroactively as of July 6th and will remain intact until one year after the official notice is published in the Federal Register.
  • All importers who have an eligible mold, are able to claim an exemption under the new exclusions, even if the importer (e.g. injection molding company) did not file for an exemption prior to the October 2018 exemption deadline.
  • At the conclusion of the government funding hiatus, CBP will issue instructions on entry guidance and implementation.
  • Once CBP issues guidance, a Post Summary Correction (PSC) or a Protest may be submitted for a refund.
  • All questions related to Section 301 entry filing requirements should be emailed to traderemedy@cbp.dhs.gov.

For further information, please reach out to Alan Rothenbuecher at 216–363–4436 or har@beneschlaw.com