How can an Importer respond to these tariffs?
Option 1: File for an Exclusion
As importers, we are certain you have justifiable reasons for opposing the proposed tariffs. To successfully file means to include a concise, meaningful and valid argument – by product.
The List 1 and List 2 exclusion filing deadlines have passed. To date, USTR has revealed over 200 HTS subheadings either completely or partially excluded from List 1 duties and 69 HTS subheadings partially excluded from List 2 duties. USTR is continuing to evaluate exclusion requests from List 1 and 2 on a periodic basis at this time.
On June 20th, USTR officials announced List 3 product exclusion submissions can be filed via online portal from June 30, 2019 at 12 PM until September 30th and retroactively apply to all products meeting the specified criteria effective September 24, 2018. To date, USTR has released 10 HTS subheadings partially excluded from List 3 duties.
If you are an importer of goods affected by List 3, don’t miss your opportunity to avoid the supplemental duties that have been imposed!
Click here to view a breakdown of our recipe for success, as well as our service offerings, in regard to filing List 3 exclusions.
The USTR will provide additional information regarding the List 4A and 4B exclusion process once it is available to the public.
How can we help? Shapiro has aligned with a Customs attorney from Thompson Coburn to assist you with crafting your argument; we will also make the filing process both easy and cost-effective for you. Please reach out to firstname.lastname@example.org for simple-to-use instruction and pricing.
Option 2: Re-evaluate your Classifications
It is always a good idea to take a second look at how your products are classified— especially when considering some binding rulings that are on file. While some classifications are straightforward, others can be very gray. Addressing these gray areas can be a difficult exercise. Oftentimes, it requires both expert interpretation of the tariff schedule (knowledge) —and expert strategies (experience).
How can we help? Shapiro has a team of licensed tariff experts on staff. Let us review your product classifications to identify the associated risks, as well as potential opportunities. Please reach out to email@example.com to get started!
Option 3: Re-evaluate your Product Designs
Let’s collaborate together! A slight modification to your product may be all that you need in terms of a legal alternative to these unanticipated tariffs. Sometimes, all it takes for a tariff adjustment is a very small design change. Remember, duty rates are determined based on the product’s condition at the time of import.
How can we help? Shapiro has a team of licensed tariff experts on staff. Let us review your product classifications to identify potential opportunities. Please reach out to firstname.lastname@example.org to get started.
Option 4: Consider Alternate Sourcing
Right now, China is the primary country under the “fairness” scrutiny. Certainly, this is subject to change. Is it possible to source your product from another country from which the additional tariffs would not apply?
How can we help? Shapiro has a team of marketing experts on staff. Let’s discuss your product line and work together to identify other potential sourcing locations. Please reach out to email@example.com to get started!
Option 5: Consider Drawback
Did you know that commodities subject to Section 301 punitive tariffs remain eligible for duty drawback? As an importer or exporter, you are still required to outlay the additional duties at the time of entry (and while the return will not be immediate); however, this option may help to mitigate your losses.
How can we help? Shapiro has a team of licensed tariff experts on staff. Let’s discuss this duty recovery opportunity together. Please reach out to firstname.lastname@example.org to get started!
We know that tariffs can be “taxing”.
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