There have been a lot of questions regarding Sec. 301 duties, and how they apply (or not) to our clients' import products. A comprehensive list of all tariff numbers subject to the various tariff actions known as Lists 1-4 can be viewed here. Lately, there has been a big push for companies to see if their products will be eligible for an official exclusion from these additional costs. We have tried to summarize the main points below regarding the current state of these exclusions and how to go about applying for one if you choose.
Exclusions have already been granted for any/all products classified under the following HTS#'s:
8412.21.0075 -- Certain Hydraulic power engines and motors
8418.69.0120 -- Self-contained drinking water coolers
8480.71.8045 -- Injection molds for rubber & plastics
The exclusion request period for goods covered under List 1 & 2 is now closed. Exclusion requests for goods covered under List 3 are still being accepted by the US Trade Representative's office. A list of the exclusion requests (3400+ so far) for goods covered under List 3 that have been received so far can be found here. Interested parties have untilSept 30, 2019to file their request for exclusion. Goods under the newly announced List 4 are not currently eligible for exclusion, and likely will not be unless the duty rates are raised to the full 25% level.
It is our recommendation that you consider engaging the services of an experienced and knowledgeable trade law firm to help prepare your exclusion request. The details for filing an exclusion can be found here.
Any exclusions granted will have an effective date back to the beginning of the trade action, so refunds of all previously-paid duties will be possible, with interest. If your goods are eligible for the exclusion, please advise your Averitt Internationalassociate so future duties can be avoided, and a process for refunding duties already paid can be added to a refund request submission.