GSP Renewed Until December 31, 2020

The renewal of the Generalized System of Preferences (GSP), which was signed by President Trump in late March, went into effect April 22, 2018. Importers should continue to flag GSP-eligible importations as SPI “A” and expected to pay normal duty rates until duty payments subsided on April 22nd.

U.S. Customs and Border Protection (CBP) will automatically process GSP-eligible refunds and informal entries filed electronically through the Automated Broker Interface (ABI) using SPI “A” as a prefix to the tariff number. To expedite the refund process, members of the Automated Clearing House (ACH) refund program should ensure all information is up-to-date and correct.

The GSP Renewal will be in phases:

Phase 1: Importers that submitted GSP entries with the SPI “A” during the lapse period should receive all refunds by mid-July 2018 from the Trade Transformation Office (TTO).

Phase 2: For entry summaries that could not be batch processed (AD/CVD, Section 232, other), CBP field personnel will receive spreadsheets to manually process those entries. According to the CBP, these spreadsheets will cover importations with the following characteristics:

  • If Section 232 duties and GSP are on the same entry line, then no GSP refund will be issued, since 19 USC 2463(b)(2) precludes GSP program benefits accruing to Section 232 goods (see below for more information).
  • If Section 232 and GSP are on different entry lines, then the GSP administrative refund should be processed manually.

Regarding post-summary correction GSP claims for importations during the lapse, according to the CBP:

  • Importers have until September 19, 2018 to submit post-importation GSP claims for goods imported during the GSP lapse on which the SPI “A” was not transmitted at entry summary.
  • GSP refund requests should be submitted as PSCs. If an entry has already liquidated, the refund request should be submitted as a protest.
  • GSP refund requests for importations made during the lapse but submitted subsequent to September 19, 2019 will be denied.
  • An importer’s failure to submit a post-importation GSP claim on or before September 19, 2018 will not be remediable via protest.