We are hearing from the media—and you may be as well– that tariffs on List 3 could go into effect as early as Friday, September 7^th.   We find this hard to believe, but feel it is important to share what we are thinking:

• The period for public comment on List 3 tariffs is officially ending on Thursday, September 6^th.  One would expect the Administration to set aside an appropriate amount of time to review comments and testimonials prior to the formal execution of any tariffs.

• With Lists 1 and 2, the Administration allowed for a few weeks to pass prior to implementation.  There is a reason for this.  This both provides Customs and Border Protection (CBP) with the necessary time to program the tariff changes and allows importers time to prepare.

With all of this said, the President seems more eager than ever to further engage China, so the possibility of a much quicker implementation date of List 3 tariffs is plausible.

We urge all potentially affected importers to contact their local congressional representatives to voice further concerns.

Shapiro will continue to monitor the situation and provide updates as they become available, as well as guidance on any exclusion process that is available.