North American Trade & Tariff Insights

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Customs and trade compliance feature story

Top Insights You Should Know about U.S. Duty Drawback

2024-07-11 | Amanda Lukas Manager, U.S. Drawback
Duty drawback can serve as an effective strategy for mitigating tariffs. Despite its complexity and time-consuming nature, with drawback, it’s possible to reclaim up to 99% of duties, taxes, and specific fees on imported goods that are subsequently exported, used in the manufacture of an exported finished product,...
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Customs and trade news

Changes to the Harmonized Tariff Schedule of the United States (HTSUS) and Schedule B

The U.S. International Trade Commission’s 484(f) Committee made changes to the HTSUS and Schedule B, effective July 1, 2024.  Visit their website to view the most updated 2024 HTSUS including the change record.

Consumer Product Safety Commission (CPSC) Pilot expanded

As part of its expanded beta pilot test, CPSC will expand the number of beta pilot test participants from 50 up to 2,000 importers and extend the test period from six months to up to three years, or until an effective date of a final rule implementing an eFiling requirement is announced.

This will allow U.S. Customs and Border Protection (CBP) to further scale the information technology (IT), procedural, and processing requirements before a final rule goes into effect.

Heightened enforcement on de minimis entries

CBP has increased enforcement on de minimis manifest entries under Section 321 and Type 86 entries. The enforcement targets vague cargo descriptions and ensures cargo is valued properly under the $800 de minimis threshold. Review the list of acceptable cargo descriptions provided by the CBP to determine the impact on your business.

Section 301 China tariff increases anticipated

On May 28, 2024, the United States Trade Representative (USTR) outlined the proposed Harmonized Tariff Schedule (HTS) subheadings that will be expecting the ad valorem tariff increases of 25%, 50%, and 100%, effective August 1, 2024, and increases in 2025 and 2026 effective on January 1 of the corresponding year.

Upcoming changes to the Complemento Carta Porte

The Complemento Carta Porte is a mandatory document for transportation across Mexican federal highways. The latest version, 3.1, is set to become mandatory on July 17, 2024. There are two main changes from version 3.0 to 3.1:

  1. Customs regime: Now allows multiple customs regimes in one document, instead of being limited to one. 
  2. Customs tariff number (HS Code): Changed from mandatory to optional for international shipments.

The Servicio de Administración Tributaria (SAT) has also updated technical documentation, FAQs, and catalogs for HazMat and ocean services. Non-compliance with these regulations can result in fines and sanctions. For assistance with compliance, reach out to a C.H. Robinson representative.


Our information is compiled from a number of sources that to the best of our knowledge are accurate and correct. It is always the intent of our company to present accurate information. C.H. Robinson accepts no liability or responsibility for the information published herein.

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Tools and resources

U.S. Tariff Search Tool

Identify duty exclusion eligibility and uncover potential duty refund opportunities. Search our HTS code look-up tool by commodity code and potentially uncover millions of dollars.

Customs Clearance Checklist

Conducting an annual review of your customs processes can help you rapidly realign processes to avoid delays or penalties. These 20 steps can help you review various areas of your trade compliance program.

Trade Strategies to Consider

Compare several trade strategies by their deployment speed, cost to implement, and risk level. Find the ones that help you properly mitigate risk and streamline processes to better control costs.

Incoterms® Tool

Who bears the risk in your transaction, and when does the risk transfer from buyer to seller? Review these shipping terms.

PARS Tracker/Rapid Lookup Service

The Pre-Arrival Review System (PARS) Tracker lets truckload and LTL carriers moving freight from the United States to Canada search for a PARS number—a way to confirm that C.H. Robinson has submitted an entry for release of the cargo from the Canada Border Services Agency (CBSA) and that the entry has been accepted by CBSA. Once an entry has been accepted by CBSA, the carrier may proceed to the border for final processing and crossing into Canada.

PAPS Tracker

The Pre-Arrival Processing System (PAPS) Tracker lets truckload and LTL carriers moving freight from Canada to the United States search for a PAPS number—a way to confirm that C.H. Robinson has submitted an entry for release of the cargo from U.S. Customs & Border Protection (CBP) and that the entry has been accepted by CBP. Once an entry has been accepted by CBP, the carrier can proceed to the border for final processing and crossing into the United States.

Canadian Logistics Forms and Links

Locate forms and resource links that support freight forwarding, customs brokerage and surface transportation in Canada.

Canadian Exchange Rate

This interactive database allows you to view the international customs exchange rates to and from the Canadian dollar for the past year. This can be useful in projecting the cost of shipments to and from various countries.

U.S. Logistics Documents

Explore forms and other documents that support your import and export strategy into and out of the United states.

Client advisories

Mitigate tariff risk, offset duties, and gain peace of mind.

Frequently asked questions


Q: What is a tariff?

Tariffs or duties are taxes assessed on imports of foreign goods, paid by the importer to the U.S. government, and collected by U.S. Customs and Border Protection (CBP). Current U.S. tariff rates may be found in the Harmonized Tariff Schedule (HTS) maintained by the U.S. International Trade Commission (ITC). The U.S. Constitution grants Congress the sole authority to regulate foreign commerce and therefore impose tariffs, but, through various trade laws, Congress has delegated authority to the president to modify tariffs and other trade restrictions under certain circumstances.1

Q: What are various types of import restrictions that can be imposed by the government?

Tariffs – A tax on imports of foreign goods paid by the importer. Ad valorem tariffs are assessed as a percentage of the value of the import (e.g., a tax of 25% on the value of an imported truck). Specific tariffs are assessed at a fixed rate based on the quantity of the import (e.g. 7.7% per kilogram of imported almonds), and are most common on agricultural imports.

Quotas – A restriction on the total allowable amount of imports based either on the quantity or value of goods imported. Quotas are in place on a limited number of U.S. imports, mostly agricultural commodities, in part due to past trade agreements to remove and prohibit them.

Tariff-Rate Quota (TRQ) –TRQs involve a two-tiered tariff scheme in which the tariff rate changes depending on the level of imports. Below a specific value or quantity of imports, a lower tariff rate applies. Once this threshold is reached, all additional imports face a higher, sometimes prohibitive, tariff rate.

Q: Does U.S. Customs and Border Protection (CBP) pay interest when refunding duties previously paid?

Yes! CBP does pay interest from the date the original money was deposited. The current interest rates are published in the Federal Register on a quarterly basis. Review the most recent Federal Register Notice for the latest rates.

Q: How much has the U.S. government collected from the various trade remedy measures?

U.S. CBP assesses and collects duties on U.S. imports, including the additional duties imposed as a result of the president’s tariff actions. As of April 27, 2022 U.S. CBP has reported these duty assessments.

Q: Have U.S. trading partners taken or proposed retaliatory trade actions?

Yes. Some United States’ trading partners subject to the additional United States import restrictions have taken or announced proposed retaliations against each of the three United States actions. The International Trade Administration published an article regarding retaliatory tariffs implemented by United States’ trading partners.

Section 301: Unfair trade practices

Q: What is Section 301?

Section 301 of the Trade Act of 1974 allows the United States Trade Representative (USTR) to suspend trade agreement concessions or impose import restrictions if it determines a U.S. trading partner is violating trade agreement commitments or engaging in discriminatory or unreasonable practices that burden or restrict U.S. commerce.

Background Report: Congressional Research Service – Section 301 of the Trade Act of 1974


Q: What aspects of Section 301 were updated in May 2024?

Some exclusions were extended through May 2025. On May 30, 2024, the United States Trade Representative (USTR) published a notice in the Federal Register regarding the 429 product-specific exclusions that were scheduled to expire on May 31, 2024.

USTR determined 164 Section 301 exclusions will be extended through May 31, 2025. These exclusions are listed in Annex C by product description. Annex D of the notice outlines the 265 exclusions that were terminated on June 14, 2024, when the exclusion transition period ended.

Q: What aspects of Section 301 were updated in December 2023?

Exclusions extended through May 2024. The Office of the United States Trade Representative (USTR) further extended the Section 301 China duty exclusions and the 77 COVID-19 related China duty exclusions through May 31, 2024.

As outlined by USTR, “The extension will also facilitate the alignment of further decisions on these exclusions with the ongoing four-year review.” Furthermore, between January 22, 2024 and 11:59 p.m. ET on February 21, 2024, public comments can be added to a docket on whether to further extend particular exclusions.

Q: What aspects of Section 301 were updated in December 2022?

Certain reinstated Section 301 duty exclusions were extended. The Office of the United States Trade Representative (USTR) announced it is extending the 352 previously reinstated product exclusions, which were retroactively made available to October 12, 2021. Originally scheduled to expire December 31, 2022, the exclusions will now be extended through September 30, 2023. The extension is effective with respect to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern standard time on January 1, 2023, and before 11:59 p.m. eastern daylight time on September 30, 2023.

What this means for your business: Uncover potential duty refunds using our U.S. Tariff Search Tool. Instantly search by Harmonized Tariff Schedule (HTS) and review the language within the “USTR Exclusion Extension Potential” section to determine your eligibility for retroactive duty recovery and for participation on a go-forward basis, through September 30, 2023.

Q: What aspects of Section 301 were updated in September 2022?

A statutory review of all Section 301 tranches was initiated. The Office of the United States Trade Representative (USTR) announced it would commence its statutory review of all active Section 301 tranches leading up to the four-year anniversary of the Section 301 China tariff actions. Accordingly, representatives of domestic industries were invited to submit their requests for continuation using the USTR’s comment portal.

In September 2022, the USTR announced it will keep the tariff actions in place and conduct a review due to requests for continuation received during the comment period and conduct a review of the actions. The USTR is seeking public comments from the trade community "to consider the effectiveness of the actions in achieving the objectives of the investigation, other actions that could be taken, and the effects of the actions on the United States economy, including consumers."

Q: How do I find out if my product is subject to Section 301 tariff duties?

Enter the product’s harmonized tariff schedule (HTS) classification on the USTR website. In addition, you can refer to our U.S. tariff search tool to quickly search both the Section 301 tariff lists, but also identify if there are any exclusion opportunities. Talk to your Trusted Advisor® expert at C.H. Robinson to learn more.

Q: Can I still apply for exclusions to the Section 301 (China) tariffs?

The time window to submit new exclusion requests is now closed. While the USTR approved, on average, 35% of requests under the first two actions, the approval rates under the third and fourth actions were 5% and 7%, respectively.3 Be sure to check in with your trusted trade advisors to see if new comment periods open.

Be aware the USTR has completed its evaluation for the potential extension of 549 specific product exclusions granted from Lists 1, 2, 3, and 4. Accordingly, on March 23, 2022, of the 549 specific product exclusions, the USTR reinstated 352 previously expired Section 301 China duty exclusions, as published in the accompanying Federal Register notice, which were retroactively made available to October 12, 2021. Originally scheduled to expire December 31, 2022, the exclusions will now be extended through September 30, 2023.

Q: Are Section 301 duties eligible for drawback?

As noted in CSMS Message 18-000419, Section 301 duties are eligible for duty drawback. Drawback is the refund of certain duties, internal revenue taxes, and certain fees collected upon the importation of goods. Such refunds are only allowed upon the exportation or destruction of goods under U.S. Customs and Border Protection supervision.

Q: Are products entered under the Section 321 de minimis exemption (under $800) subject to Section 301 duties?

No, not right now. Goods properly entered under Section 321 are not subject to Section 301 duties. Please note that a formal entry is required if a shipment contains merchandise subject to AD/CVD. Goods subject to AD/CVD do not qualify for Section 321.

Something to keep an eye on: U.S. Customs and Border Protection (CBP) submitted a proposal in early September 2020 to the Office of Management and Budget that would eliminate the $800 de minimis exemption for goods subject to Section 301 tariffs. Additionally, in January 2022, the Import Security and Fairness Act was introduced to address Section 321 shipment activity. Significant changes proposed within this legislation are as follows:

Remember, Section 321, 19 USC 1321 is the statute that describes de minimis. De minimis provides admission of articles free of duty and of any tax imposed on, or by reason of importation, but the aggregate fair retail value in the country of shipment of articles imported by one person on one day and exempted from the payment of duty shall not exceed $800. The de minimis threshold was previously $200 but increased with the passage of the Trade Facilitation and Trade Enforcement Act (TFTEA).

Q: If I previously paid Section 301 (China) duties, but an exclusion was later issued by the United States Trade Representative (USTR), can I get my money back?

Yes. You have the opportunity to potentially recover duties paid on previous entry activity. Your customs broker, trade attorney, or trade consultant can submit a refund request via Post Summary Correction (PSC) or Protest as long as the entry has not exceeded the liquidation date plus 180-day time period (roughly 480 days from the original entry date). Remember, your company doesn’t have to be the one that requested the exclusion in the first place. You qualify as long as your product meets the specific description of the exclusion granted by the USTR.

Q: Are products used to support the fight against COVID-19 subject to the additional Section 301 (China) tariffs?

The USTR announced on March 20, 2020, that, prior to the COVID-19 outbreak, the agency had been working with the U.S. Department of Health and Human Services “to ensure that critical medicines and other essential medical products were not subject to additional Section 301 tariffs.” Consequently, the United States had not imposed tariffs on certain critical products, such as ventilators, oxygen masks, and nebulizers.

The USTR has since reviewed requests for exclusions on medical care products, resulting in exclusions granted on basic medical supplies, including gloves, soaps, face masks, surgical drapes, and hospital gowns. Since March 2020, the USTR has exempted certain medical products from Section 301 tariffs in several rounds of exclusions.3

Q: What is the timing of duty calculations on immediate transportation in bond entries subject to Section 301?

Duties are due on goods that are entered for consumption, or withdrawn from warehouse for consumption, on or after the effective date of the provisional tariffs. For entries covered by an entry for immediate transportation, and with a country of origin of China, and a Harmonized Tariff Schedule (HTS) classification covered by Annex A to the FRN, such entries shall be subject to the duty rates in effect when the immediate transportation entry was accepted at the port of original importation, pursuant to 19 CFR 141.69 (b), which states:

Merchandise which is not subject to a quantitative or tariff-rate quota and which is covered by an entry for immediate transportation made at the port of original importation, if entered for consumption at the port designated by the consignee or his agent in such transportation entry without having been taken into custody by the port director for general order under section 490, Tariff Act of 1930, as amended (19 U.S.C. 1490), shall be subject to the rates in effect when the immediate transportation entry was accepted at the port of original importation.

Q: Are products of Hong Kong subject to the additional Section 301 duties against China?

No. Additional duties imposed by the Section 301 remedy only apply to articles that are products of the People’s Republic of China (ISO Country Code CN). Imported goods that are legitimately the product of Hong Kong (HK) or Macau (MO) are not subject to the additional Section 301 duties. Please note that Section 301 duties are based on country of origin, not country of export.2

Q: Do Section 301 (China) duties still apply if I ship goods to another country, such as Canada or Mexico, and have them packaged there before entering the commerce of the United States?

Yes. Basic changes/processes such as packaging, cleaning, and sorting would not change the country of origin to be declared in most cases. The origin would still be China and therefore the Section 301 duties would still apply.

Section 232: National security concerns

Q: What is Section 232?

A Section 232 of the Trade Expansion Act of 1962 allows the president to adjust imports if the Department of Commerce finds certain products are imported in such quantities or under such circumstances as to threaten to impair U.S. national security.

Background Report: Congressional Research Service – Section 232 Investigations: Overview and Issues for Congress

Section 201: Cause/threat to domestic industry

Q: What is Section 201?

A Section 201 of the Trade Act of 1974 allows the president to impose temporary duties and other trade measures if the U.S. International Trade Commission (ITC) determines a surge in imports is a substantial cause or threat of serious injury to a U.S. industry.

Background Report: Congressional Research Service – Section 201 of the Trade Act of 1974 – August 2018


  1. Congressional Research Service – Trump Administration Tariff Actions (Sections 201, 232, and 301): FAQs
  2. Section 301 Trade Remedies Frequently Asked Questions
  3. Congressional Research Service - Section 301: Tariff Exclusions on U.S. Imports from China

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All content and materials discussed herein are for informational purposes only and do not constitute legal advice. You should always independently check the related Code of Federal Regulations (CFR) and, if needed, consult with the applicable Federal Agency (e.g. CBP, USTR) and/or external counsel where any question or doubt exists. Information on this site is the property of C.H. Robinson. Any transmission or use without C.H. Robinson’s permission and approval is not allowed or authorized.