Additional Updates on China Tariffs and Importer Requirements on Origin

  • Effective Date: May 16, 2024
  • Affected Regions: North America
  • Advisory Type: Tariff

Dear Valued Customer,


USTR proposes exclusion process for certain machinery and solar manufacturing equipment


On May 14, 2024, the U.S. Trade Representative (USTR) issued the “Four-Year review of Actions Taken in the Section 301 Investigation”. In addition to the proposed modifications to Section 301 China tariffs, the Trade Representative is proposing the establishment of an exclusion process targeting machinery used in domestic manufacturing, including proposals for 19 exclusions for certain solar manufacturing equipment. The proposed exclusion process will be limited to machinery under certain 8-digit tariff lines in Chapter 84 and Chapter 85 of the Harmonized Tariff Schedule of the United States (HTSUS). This is outlined in Appendix K and Appendix L of the report. A Federal Register Notice is expected to be issued next week with further instructions on the process and comment period.


For information on the specific products expecting increases, review our client advisory.

Tariffs to be raised on goods made in China (



CBP guidance on compliance with origin documentation for preference programs


On May 14, 2024, U.S. Customs and Border Protection (CBP) issued guidance instructing importers of their obligations to be compliant in the issuance of origin declarations, origin statements and certificates of origin. These declarations and statements of origin “must be signed by an official of the importer, exporter or producer or agent of the importer, exporter, or producer having knowledge of the relevant facts to the origin of the goods, as specified by the respective trade preference program.”


The notice states that CBP may deny a claim for preferential tariff treatment if an importer fails to submit completed origin documentation when requested by CBP. CBP has recently found “an increase in the use of the consignee information on these forms where the importer information is required.”


For more information on this notice and the origin requirements for preferential trade programs:


CSMS # 60588866 - GUIDANCE: Importer Obligation & Requirements in completing Origin documents - Declarations, Statements, and Certifications of Origin (


Thank you for being a Valued Customer.  If you have any questions, please do not hesitate to contact your C.H. Robinson commercial representative for further information.


C. H. Robinson