• Advertise
  • Contact Us
  • About Us
  • Supplier Directory
  • SCB YouTube
  • Login
  • Subscribe
  • Logout
  • My Profile
  • LOGISTICS
    • Air Cargo
    • All Logistics
    • Express/Small Shipments
    • Facility Location Planning
    • Freight Forwarding/Customs Brokerage
    • Global Gateways
    • Global Logistics
    • Last Mile Delivery
    • Logistics Outsourcing
    • LTL/Truckload Services
    • Ocean Transportation
    • Rail & Intermodal
    • Reverse Logistics
    • Service Parts Management
    • Transportation & Distribution
  • TECHNOLOGY
    • All Technology
    • Artificial Intelligence
    • Cloud & On-Demand Systems
    • Data Management (Big Data/IoT/Blockchain)
    • ERP & Enterprise Systems
    • Forecasting & Demand Planning
    • Global Trade Management
    • Inventory Planning/ Optimization
    • Product Lifecycle Management
    • Sales & Operations Planning
    • SC Finance & Revenue Management
    • SC Planning & Optimization
    • Sourcing/Procurement/SRM
    • Supply Chain Visibility
    • Transportation Management
  • GENERAL SCM
    • Business Strategy Alignment
    • Education & Professional Development
    • Global Supply Chain Management
    • Global Trade & Economics
    • HR & Labor Management
    • Quality & Metrics
    • Regulation & Compliance
    • SC Security & Risk Mgmt
    • Supply Chains in Crisis
    • Sustainability & Corporate Social Responsibility
  • WAREHOUSING
    • All Warehouse Services
    • Conveyors & Sortation
    • Lift Trucks & AGVs
    • Order Fulfillment
    • Packaging
    • RFID, Barcode, Mobility & Voice
    • Robotics
    • Warehouse Management Systems
  • INDUSTRIES
    • Aerospace & Defense
    • Apparel
    • Automotive
    • Chemicals & Energy
    • Consumer Packaged Goods
    • E-Commerce/Omni-Channel
    • Food & Beverage
    • Healthcare
    • High-Tech/Electronics
    • Industrial Manufacturing
    • Pharmaceutical/Biotech
    • Retail
  • THINK TANK
  • WEBINARS
    • On-Demand Webinars
    • Upcoming Webinars
    • Webinar Library
  • PODCASTS
  • VIDEOS
  • WHITEPAPERS
Home » Blogs » Think Tank » Are Your Products Eligible for Tariff Refunds? Here's What to Know

Think Tank
Think Tank RSS FeedRSS

Are Your Products Eligible for Tariff Refunds? Here's What to Know

Port of Shanghai
An aerial view of the Port of Shanghai in Shanghai, China. Photo: Getty Images.
June 16, 2022
Ben Bidwell and Anahi Czeszewski, SCB Contributors

As the global supply chain grapples with continued disruption, shippers face immense challenges to keep goods moving, meet customs requirements and manage costs.

More than 60% of shippers say that pressure to reduce costs is among their top three pain points for 2022, according to a January survey by C.H. Robinson. One of the ways they can identify significant cost savings right now is by determining their eligibility under tariff exclusions that were recently reinstated by the United States Trade Representative (USTR).

On March 23, 2022, USTR announced it will reinstate through the end of this year more than 350 previously expired China duty exclusions under Section 301 of the Trade Act of 1974, retroactive to October 12, 2021. The reintroduced exclusions apply to any product that originates in China and meets the description in the exclusion, regardless of who is importing. It’s important to act now to identify qualifying exclusions and estimate potential duty refund amounts.

A brief background: In late 2021, USTR began the process of evaluating 549 specific product exclusions with the possibility of granting extensions. Most expired as of December 31, 2020. Following a public comment period, which concluded on December 1, 2021, USTR completed an in-depth review of submitted comments with the advice of advisory committees, the interagency Section 301 committee, and the White House COVID-19 Response Team.

As stated in this press release, USTR reinstated 352 previously expired Section 301 China duty exclusions.

So now what? To request a refund of Section 301 duties paid on previous imports of products granted duty exclusions by USTR, importers may file a Post Summary Correction if within the PSC filing timeframe — up to 15 days prior to the scheduled liquidation date, which is generally 300 days from date of entry summary filing. If the entry is beyond the PSC filing timeframe, importers may file a protest if within the protest filing timeframe, which is 180 days following liquidation of the impacted entry.

As reinstated exclusions are available only for products that meet the specific description in the product exclusion language, importers requesting an administrative refund for previously paid duties, whether through a PSC or protest, must provide supporting information to U.S. Customs and Border Protection (for example, product literature, descriptive illustrations and product specifications), and correlate this information clearly to each applicable entry line to ensure proper filing.

Shippers should expect a high level of scrutiny by CBP during the documentation review. They must ensure that PSC or protest paperwork is organized and clearly conveyed when uploading this documentation to CBP, or providing it to a customs broker for uploading.

There are tools available to help shippers more easily and quickly understand their duty recovery potential, such as the U.S. Tariff Search Tool. Shippers can input their organization’s Harmonized Tariff Schedule (HTS) code and receive information about their eligibility under the tariff exclusions to better understand their total landed cost. The tool allows shippers to easily identify retroactive and prospective exclusion opportunities by using the 10-digit tariff classification codes, as queried directly from both the U.S. International Trade Commission (USITC) and all duty-exclusion notices published by USTR, including the most recent one from March 23, 2022.

Under the Senate’s U.S. Innovation and Competition Act (USICA), there may be additional opportunities to collect refunds on Section 301 China duties previously paid to CBP. According to the bill, all previously expired duty exclusions would be reinstated from the date of passage of the legislation through December 2022.

The USICA and House of Representatives’ response to it, the America COMPETES Act, are both under deliberation, and lawmakers will need to reach a compromise on the differences between the bills before a final bill can go to President Biden’s desk for signing. Notably, the America COMPETES Act does not contain any provisions to reinstate previous duty exclusions to the Section 301 China duties.

Shippers need to understand how the recent USTR announcement might affect their supply chains, and identify steps to help mitigate risk and maximize cost-savings opportunities.

Ben Bidwell is director of North America customs and compliance, and Anahi Czeszewski is product development manager, with C.H. Robinson.

Sourcing/Procurement/SRM Global Supply Chain Management Global Trade & Economics Regulation & Compliance

RELATED CONTENT

RELATED VIDEOS

Subscribe to our Daily Newsletter!

Timely, incisive articles delivered directly to your inbox.

Popular Stories

  • DOCUMENTS BEARING THE INSIGNIA OF US CUSTOMS AND BORDER PROTECTION LIE ON A TABLE

    New CBP Regs Call for Greater Diligence by Brokers in Reporting Security Breaches

    Freight Forwarding/Customs Brokerage
  • A WORKER IN A WAREHOUSE, SUPERIMPOSED WITH GRAPHICS SHOWING SUPPLY NETWORK

    Enabling Intelligent Visibility With Supply Chain Analytics

    Data Management (Big Data/IoT/Blockchain)
  • GSCMS-Promo.png

    Watch: Introducing the Global Supply Chain Marketing Summit

    Education & Professional Development
  • A HAND TURNS A LARGE, LIGHTED DIAL WITH THE WORD RISK ON IT iStock-NicoElNino-1364371014.jpg

    Measuring KPIs and KRIs for Comprehensive Supplier Performance Management

    Technology
  • DEEPLY CRACKED EARTH UNDER A BLUE CLOUDY SKY

    Why Maritime Supply Chains Must Adapt to Sustainability Regulations

    Ocean Transportation

Digital Edition

Scb nov 2022 sm

2022 Supply Chain Innovator of the Year

VIEW THE LATEST ISSUE

Case Studies

  • New Revenue for Cloud-Based TMS that Embeds Orderful’s Modern EDI Platform

  • Convenience Store Client Maximizes Profit and Improves Customer Service

  • A Digitally Native Footwear Brand Finds Rapid Fulfillment

  • Expanding Apparel Brand Scales Seamlessly with E-Commerce Technology

  • How a Global LSP Scaled its Security Program and Won More Business

Visit Our Sponsors

Orderful Yang Ming Alithya
Barcoding Blue Yonder BNSF Logistics
CoEnterprise Data Capture Deposco
E2open GAINSystems Generix
Geodis GEP GreyOrange
Here Honeywell Intelligrated IFM
Infor Inmar Keelvar
Kinaxis Korber Lean Solutions Group 2H
Liberty SBF Locus Robotics Logility
LogistiVIEW Lucas Systems MCA Connect
MPO Nvidia Old Dominion
OpenText ORTEC Overhaul
Parsyl PMMI QIMA
Redwood Logistics Ryder E-commerce by Whiplash Saddle Creek Logistics
Schneider Dedicated Setlog Holding AG Ship4WD
Shipwell Tecsys TGW Systems
Thomson Reuters Tive Trailer Bridge
Vecna Robotics Verity
Verusen
  • More From SCB
    • Featured Content
    • Video Library
    • Think Tank Blog
    • SupplyChainBrain Podcast
    • Whitepapers
    • On-Demand Webinars
    • Upcoming Webinars
  • Digital Offerings
    • Digital Issue
    • Subscribe
    • Manage Your Subscription
    • Newsletters
  • Resources
    • Events Calendar
    • SCB's Great Supply Chain Partners
    • Supplier Directory
    • Case Study Showcase
    • Supply Chain Innovation Awards
    • 100 Great Partners Form
  • SCB Corporate
    • Advertise on SCB.COM
    • About Us
    • Privacy Policy
    • Contact Us
    • Data Sharing Opt-Out

All content copyright ©2023 Keller International Publishing Corp All rights reserved. No reproduction, transmission or display is permitted without the written permissions of Keller International Publishing Corp

Design, CMS, Hosting & Web Development :: ePublishing