Grace Period Extended for Increase in 301 China Tariffs – Enter U.S. Imports before June 15

On June 10, 2019, the United States Trade Representative (USTR) published a Federal Register notice providing that products from China covered by the third tranche (List 3) of Section 301 tariffs, which were exported to the U.S. prior to May 10, 2019, must be entered into the U.S. before June 15, 2019, to avoid the additional 25 percent duty.  The published notice can be read here.
 
In a prior notice published on May 9, 2019, USTR increased the rate of additional duties from 10 percent to 25 percent for the List 3 Chinese products (i) entered for consumption, or withdrawn for warehouse for consumption, on or after 12:01 a.m. eastern daylight time on May 10, 2019, and (ii) exported to the United States on or after May 10, 2019.  U.S. Customs and Border Protection later clarified that goods “on the water” before May 10, 2019, must be entered before June 1, 2019, to avoid the tariff increase.  The June 1, 2019, deadline has now been extended to June 15, 2019.  USTR cites “customs enforcement factors and the transit time for goods exported from China” as the reasoning for this extension.
 
Thus, the 10-percent duty remains in effect for List 3 Chinese goods exported before May 10, 2019, and entered the U.S. before June 15, 2019.  The 25-percent duty will apply to List 3 Chinese goods entered on or after June 15, 2019, regardless of the export date.
 
For more information, please contact a BDO Customs and International Trade Services professional.