To Our Valued Customers:

 

The Covid-19 situation impacting all of us is continuously evolving and we want to continue to advise what we are seeing and experiencing in the market. At Laufer, we are committed to providing you with as much information as possible as quickly as possible, understanding, of course, that events are quite fluid and changing rapidly.

Here is a short list of what we are seeing this week:

 

US Customs & Participating Government Agency Operations (CBP & PGA): CBP has advised they are 100% operational at this time, although many employees are working from home around the country. In some port-specific cases, CBP has verbally committed to granting additional days on entry submissions during the crisis. Many ports have issued standard ‘potential delays’ notices. Some processes and procedures for paper document submission have been altered. Specific issues should be handled directly with the port of entry. We will most likely begin to see some back ups and additional exams through Customs and some PGAs – FDA specifically, with the surge of increased imports of medical and emergency relief products.

 

NEW UPDATES AS OF 3/26: 

Duty Deferral: CBP is no longer accepting individual requests for duty deferral as of 3/26. Additionally, payments for deferred duties that were granted between 3/20-3/26 must be initiated by 3/27.

Section 301: The USTR has granted new Section 301 exclusions for some medical products (and smart watches) on List 4A which fall under these descriptions:

Coverings, of plastics, designed to fit over wound sites or casts thereby forming a protective seal for keeping the covered area dry and debris free while showering or bathing (described in statistical reporting number 3926.90.9990)

Pouches of plastics, of a kind used with manually operated pill or tablet crushers to capture the powdered medicaments (described in statistical reporting number 3926.90.9990)

Refillable dispensers of plastics, designed for mounting on a vertical wall, of a kind used to store and dispense emesis containment bags in medical settings (described in statistical reporting number 3926.90.9990)

Sterile urology drain bags of plastics, designed to fit over a urology table extension, with a flap extension that provides sterile separation of the patient from the table surface and directs fluids into and through a filter at the top of an attached drain hose leading to a collection container (described in statistical reporting number 3926.90.9990)

Ice bags of textile materials, for treating injuries or soreness, each refillable (described in statistical reporting number 6307.90.9889)

Identification wristbands of textile materials, each with a blank panel (described in statistical reporting number 6307.90.9889)

Apparatus suitable for wearing on the wrist, having time-display functions, each article having an accelerometer and being capable of displaying and transmitting data sent to it by a network (e.g., portable ADP unit, LAN or cellular network) (described in statistical reporting number 8517.62.0090)

 

Will Duty Payment Terms be Extended? The National Customs Brokers and Freight Forwarders Association (NCBFAA) has sent a letter to CBP asking for consideration of a blanket duty payment extension of 90 days. CBP is currently considering what’s feasible and granting some individual, case-by-case deferral requests at this time. Although many importers are asking great questions about duty deferral (Such as: Who is eligible? How do I make the request? What information is required in the request? Do I need to be on my own ACH to qualify? How is PMS impacted? When will the duty deferral begin? Are recently cleared goods eligible? How many more days do I have to pay?), there are no further specifics or additional details available at this time. Official notice and more information could come through the Federal Register or an Executive Order. There is no official timeframe given on length of duty extensions, but some of those already granted have been for an additional 10 days.

When requesting a duty deferral, importers should provide as much information as possible and send submissions to OTentrysummary@cbp.dhs.govSome example data to include: Company full legal name, address, IOR #, import information, why you are asking for the extension, and what harm your company is experiencing due to current market conditions.

Liquidated damages notices for late duty payments will still be auto-generated, but are superseded by extension approval notices.

We will advise when an official notice is available with more details.

 

Entry Protest and Bond Insufficiency Extensions: Currently, CBP has no plans to extend Entry Protest timelines. CBP will, however, give importers more time to comply with bond insufficiency issues. Providing a 10 day extension for termination and replacement of insufficient bonds with due dates in March. There is no postponement of April bond sufficiency reviews at this time. The situation will continue to be monitored.

 

Section 301 and 232 Tariffs: A request to lift tariffs associated with Section 301 and 232 has reached the President. If this request is not granted, there are hopes for specific provisions to be added to the Covid-19 economic support and stimulus package in one of 3 ways: 1) Suspend or reduce existing tariffs until the state of emergency is over 2) Prohibit the implementation of any additional tariffs during the state of emergency 3) Direct CBP to refund Section 301 and 232 duties which have already been paid.

 

This is a developing situation that will continue to be monitored.

Meanwhile, additional exclusions are continuing to be granted on a rolling basis providing importers some relief on particular products. The latest rounds have come out in just the last couple of weeks from products on List 3 and List 4A.As always, our customers can find the latest updates pertaining to Section 301 on our Laufer.com landing page: http://www2.laufer.com/tariffs.html

We truly appreciate all your support as we navigate this event together. Should you need any additional information or guidance, please feel free to contact your Laufer sales or team member.

 

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