First Batch of Products Exclusions 301

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First Batch of Products Exclusions 301

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26-Dec-18

First Batch of Products Exclusions 301

The US Trade Representative Issued its first list of product exclusions for 301 tariffs on Chinese goods, granting full or partial exemptions for 22 10-digit tariff subheadings. The product exclusions apply retroactively to July 6, addressing the List 1 products from the original tariff increases on $34 million worth of goods.

Unlike the 232 exclusions, all importers may take advantage of the 301 exclusions if their products are among the excluded tariff numbers. We are awaiting notice from CBP on specific "instructions on entry guidance and implementation".

Fully exempt from Section 301 duties are subheadings 8412.21.0075, 8418.69.0120, 8480.71.8045, 8482.10.5044, 8482.10.5048, 8482.10.5052 and 8525.60.1010. These subheadings cover certain hydraulic power engines, drinking water coolers, injection molds, radial bearings, and CB radio transceivers.

USTR also created partial exemptions for products of 15 other digit-subheadings that meet the additional requirements of product descriptions included in an annex to USTR’s notice. These partial exemptions include some outboard marine engines of subheading 8407.21.0080, some salad spinners in 8421.19.0000, some water filtration apparatus of 8421.21.0000, some winches of subheading 8425.39.0100, some elevators of subheading 8428.32.000, and some belt conveyors of 8428.33.0000.

Also partially excluded are some papermaking machinery and components found in subheadings 8419.90.2000, 8420.10.9080, 8439.99.1000 and 8439.99.1000, some work stands for miter saws of subheading 8466.92.5010, some angle cock handle assemblies of 8481.90.9040, some radiation therapy systems of subheading 9022.14.0000, and some thermostats for HVAC systems of subheading 9032.10.0030.

New subheading 9903.88.05 will be used for these products, as well as others excluded from the first tranche of Section 301 tariffs (i.e., those that would otherwise be covered by subheading 9903.88.01). The new provisions have yet to be added to the tariff schedule by the International Trade Commission. The new exclusions stem from about 1000 exclusion requests, and about 8,550 more requests are still pending, according to a list on USTR’s website. About 1,250 have been denied.

Although these first exclusions cover a limited number of products and took almost five months to be issued it is good to see there is some hope that exclusion requests will be given serious consideration. We will keep you advised of further developments.