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Section 301 Tariffs Update

This past weekend, President Trump and President Xi Jinping of China agreed to a temporary cease-fire for the ongoing trade dispute between the US and China. The agreement did not provide any concrete breakthroughs in resolving the fundamental conflict, but it did provide another chance for negotiators to attempt to forge a permanent accord.

President Trump advised that the United States would not impose any new tariffs on Chinese exports while talks were underway, and that China had agreed to resume broad purchases of American farm products and other goods. The Saturday developments delay the imposition of 25 percent tariffs on $300 billion in Chinese imports.

While it remains to be seen what the full impact of the newest developments will be, we have four Section 301 Tariffs updates to provide to you at this time.

  1. The proposed list 4 is currently on hold. This was decided at the G20 Summit, where the President indicated that for now, the proposed Section 301 Tariff List 4 will not go into effect. The proposed List 4 includes the vast majority of the remaining HTS numbers that are not already on Lists, 1, 2, or 3, which are currently in effect now.

There was a public hearing on June 17 in Washington, and there are currently 2775 comments logged against this docket, which are overwhelmingly against the implementation of additional tariffs.

So far, there is not an official announcement on the status of List 4, either via the United States Trade Representative, the Federal Register, or the White House. However, as stated via the G20 summit media coverage in Osaka last week, per President Trump, there will be no more tariffs at this moment. 

You can find a detailed timeline of the US/China trade war, as provided by the Law Firm of Dezan Shira &Associates.

The three remaining points relate to the Section 301 Tariff Lists (1, 2 & 3) that are already in effect, but now have exclusions. This means that if you have an item classified on the Section 301 Tariff List 1, it is possible that an exclusion has been granted.  List 2 items are currently in the review process. List 3 items are accepting exclusion requests through Sept 30, 2019.

  1. Exclusions were granted on the Section 301 Tariff List 1 in 5 sets of exclusions, since December of 2018. The final set was issued on June 4, 2019. It is important to review if your product is on the Section 301 Tariff List 1 to see if you potentially qualify for an exclusion that has been granted.

 

  1. The Section 301 Tariff List 2 exclusion requests were due on December 18, 2018. Currently, these List 2 exclusion requests are still under review. You can find all denied and pending List 2 exclusion requests here.

 

  1. The Section 301 Tariff List 3 exclusion request submission instructions were just released.  The exclusion request period opened on June 30, 2019,  and closes on September 30, 2019. Please see the FAQ on how to submit an exclusion request for List 3.

Should you have questions in regards to this situation, please contact Compliance@rimlogistics.com. RIM logistics, ltd. will continue to monitor the changes and effects of news that impact global trade and keep you informed as we receive updated information.