To Our Valued Customers:

 

Section 301 (China Tariffs) and Hong Kong: As discussions become increasingly tense with China, there is worry from the US import community that some tariff relief achieved through the Phase 1 Trade Deal may be in jeopardy. Additionally, Hong Kong has been receiving preferential treatment and has not been subject to the same tariffs as China, but that special trade status is now also being questioned and evaluated.

 

New Exclusions: Exclusions are continuing to be granted on a rolling basis which is providing importers some relief on particular products. More exclusions were granted as recently as June 9. These exclusions will allow importers to file for retroactive refunds of duties already paid, and avoid paying additional duty on upcoming imports while the exclusion is valid. To verify exclusion qualification, importers should check the lists very carefully against their product details and work with their customs broker to prepare the associated filings.

 

Exclusion Expirations and Extensions: Exclusions are also starting to expire. Even some new exclusions granted on May 28 will start to expire as soon as August 7. This means these new exclusions, which importers may still be evaluating applicability for their products, are already in the comment period to request an extension. Prior to reaching the expiration date on each exclusion, the USTR opens a ‘comment period’ for importers to request exclusion extensions. Just like initial exclusion requests, the USTR requires certain information to be included in the request – including company revenue, import activity, and a business case.

 

It’s crucial that importers act within these short ‘comment’ windows if they wish to request extensions to their exclusions. Each product with an exclusion applicable will require a separate comment, and the comment periods are different and separate for each round of exclusions.

The comment period for some exclusions on List 1 and List 3, which were initially granted in April and May of 2020, is open now through July 1, 2020.

Importers who wish to draft comments requesting exclusion extensions should act now before the window on these particular exclusions closes.

We are currently assisting importers in drafting their comment submissions. Contact your Laufer representative for more details on the process and requirements.

 

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