Recent Trade & Tariff Perspectives

January 11, 2023  |  Ivana Gavroski  Product Development Manager

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Hundreds of Section 301 China Tariff Exclusions Extended—Here’s What to Know

The Office of the U.S. Trade Representative (USTR) recently extended hundreds of Section 301 China Tariff exclusions for goods ranging from seafood to automotive products. Read on for insights on determining if your products may be covered and how to navigate these recent developments. 

Brief overview of the imposed tariffs and statutory review process

The Section 301 China Tariffs were implemented in 2018 after a USTR investigation into China’s trade practices found that certain Chinese policies and practices were unreasonable or discriminatory and burdened or restricted U.S. companies and workers. In response to these findings, the U.S. imposed tariffs—adding 7.5% and 25% to certain products imported from China—amounting to an estimated $1.1 billion in assessed duties as of January 4, 2023.

By law, the tariffs expire after four years unless a representative of a domestic industry that benefited from the tariffs submits a written request for continuation. On October 12, 2022, the USTR announced phase two of the statutory four-year review following requests for continuation from domestic industry representatives, keeping the tariffs in effect until further notice.

As part of the review, the USTR is now seeking public comments from interested parties through January 17, 2023, on the effectiveness of the actions in achieving the objectives of the investigation, other actions that could be taken, and the effects of such actions on the U.S. economy, including consumers.

Exclusions recently extended for certain products

The USTR most recently extended exclusions for:

If these recent exclusions include any of your company’s products, you may submit comments through the USTR portal as part of the four-year review by the January 17, 2023, deadline.

How to apply the exclusions

Most exclusions are product-specific, meaning your company’s products need to meet the specific USTR descriptions in the corresponding Federal Register Notices. You also need to verify the classification of your products under the Harmonized Tariff Schedule of the United States (HTSUS) codes, since the HTSUS governs each exclusion.

In addition, you need to keep track of the deadlines associated with these exclusions, both for future and past customs entries. The deadline to apply the exclusions varies depending on different factors, such as the date of the entry and the exclusion being applied.

If you need assistance reviewing or classifying your products, C.H. Robinson has a dedicated classification team that can help.

Simplify the exclusion process – let C.H. Robinson help

To quickly and conveniently see if any exclusions may apply to your products, leverage our free U.S. Tariff Search Tool to get an easy-to-understand report. Using the tool, you can also gain clarity into your import costs and identify opportunities to potentially reduce or eliminate duties and fees. Learning how to get started with the U.S. tariff search tool takes less than a minute.

In addition, you can manage your consolidated customs activity with our U.S. Customs Analytics tool in Navisphere® and easily see what exclusions you have claimed. You can also determine how renewal or expiration of these exclusions will impact your landed costs. The U.S. Customs Analytics tool provides strategic insights into where you can potentially mitigate risk, reduce cost, and measure on-time entry performance—all while staying on top of ever-changing trade policy and customs requirements.

Stay current

Changes to the Section 301 China Tariffs and exclusions are ongoing and complex. Subscribe to our Client Advisories to be among the first to know when changes take place. Connect with one of our Trusted Advisor® experts to learn more. 

Additional resources

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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