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, 2, 3 and 4A exclusion filing deadlines have passed. To date, USTR has revealed approximately 700 HTS subheadings either completely or partially excluded from List 1 duties, 250 HTS subheadings partially excluded from List 2 duties, roughly 890 HTS subheadings from List 3 duties and 216 HTS subheadings from List 4A duties.

Officials have also begun considering whether or not product exclusions should be extended for up to an additional 12 months from their current expiration date(s). As of October 1, 2020, the USTR has issued extensions to certain products from 10 rounds of exclusions from List 1, 4 rounds of exclusions from List 2, 15 rounds of exclusions from List 3, and 8 rounds of exclusions from List 4A. Click HERE to view all exclusion extensions announced thus far.  

The USTR is continuing to evaluate requests from List 1, 2, 3 and 4a on a periodic basis. 

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 [email protected] 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 protected] 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 [email protected] 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 protected] 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 [email protected] to get started!

We know that tariffs can be “taxing”.

Shapiro is a powerful partner. Give us a call. We are here to help!