Section 301 Duty Recovery in a Pandemic

Posted by Jim Conrad
Blog originally posted on 09/06/2020 12:28 PM


It’s been an extraordinary year in international trade. Higher duties, more complex supply chains driven by trade actions, and a pandemic that has left many businesses understaffed in important areas.

Conceptually, the work from home model helps but it can be difficult to implement a coordinated effort to compliantly conduct international trade and mitigate costs. Eventually, these duty recoveries can be lost by uncertainty.

The U.S. Trade Representative has established a process by which particular products may be excluded from Section 301 duties imposed on good originating from China. The details regarding these excluded products are enunciated in Chapter 99, U.S. Note 20 of the U.S. Harmonized Tariff and in various Federal Register Notices. 

These thousands of exclusions can be declared at the time of import entry or retroactively, as we have noted in previous postings, through post entry submissions to Customs and Border Protection.  There are new product exclusions, extensions for previously granted exclusions as well as expiring ones, all requiring significant expertise and investigative time. 

Section 301 duty recovery is also available for products that are imported and subsequently exported either in the same condition or incorporated into manufactured products.  There are great opportunities for both small and large importers, however, chasing these recoveries oftentimes takes a back seat to running the operation during these difficult times.

Tradewin has been at the forefront of the recovery effort and continues to retain its complete staff to assist importers with their duty recovery efforts.  We have the expertise and experience to help in the recovery initiative

In the meantime, here is the most current exclusion listing at the time of this writing; a small slice of the available Section 301 exclusions that are available to importers. Check out our other blog on recovering Section 301 duties.

Enjoy the good weather and stay safe.

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Topics: Duty Drawback, Section 301

Blog originally posted on 09/06/2020 12:28 PM

Jim Conrad

Written by Jim Conrad

Jim joined Tradewin in 2009, continuing a successful career in international logistics and trade compliance that began in 1980. He has spent more than three decades in leadership roles overseeing international trade compliance including the positions of corporate Director of Operations and as Chairman of the Board of Directors for a large U.S. shipper’s association. Jim’s technical background covers a wide range of international trade areas including harmonized tariff classification, valuation, anti-dumping and risk analysis. Jim is a graduate of North Shore Community College and majored in Business Administration at Salem State University. He is a member of the International Compliance Professionals Association and a U.S. Licensed Customs House Broker.