We would like to remind you that List #3 under Section 301 for the Chinese Tariff Sanctions which is currently at 10% in additional duties is still scheduled to increase to 25% for any shipments entered, or withdrawn from warehouse for consumption in the United States as of 12:01 AM Eastern Standard Time on January 1, 2019. There are some rumors floating around that the implementation date may change to a different date early in January, but the only person authorized to make such a change is the United States Representative (USTR) under the mandate from the President. As of today, there has not been such an official announcement made by the USTR, thus the January 1st, 2019 date for the increase remains officially in place. The list of affected tariffs which we have previously published before their corresponding implementation dates can be accessed through the following links:
List 3: https://ustr.gov/sites/default/files/enforcement/301Investigations/Tariff%20List-09.17.18.pdf
List 2: https://ustr.gov/sites/default/files/enforcement/301Investigations/Final%20Second%20Tranche.pdf
List 1: https://ustr.gov/sites/default/files/enforcement/301Investigations/List%201.pdf
The driver date for the January 1st increase to 25% additional duty from 10% for tariffs in List 3 will be the arrival date to the United States. Merchandise arriving in 2018 which is not subject to quantitative or tariff-rate quota and covered by an Immediate Transportation (IT) made at the port of original importation and accepted or approved by Customs in 2018 will be subject to the duty rates in effect in 2018 (currently 10% additional duty). However, if the goods arrive to the United States in 2019, even though they may have been preliminarily or conditionally released by Customs in 2018, the 25% duty rate will apply simply because the official date of entry cannot be prior to the date when the goods arrive within the U.S. port limits.
It is highly recommended that any orders with merchandise affected by List 3 that are pending shipping be carefully reviewed by the supply chain team. If the proper and immediate course of action is taken, and the goods arrive and clear Customs in accordance with the timeframes stipulated above, it may be possible to save the 15% duty increase that will be implemented on January 1st.
Should there be any changes, we will let you know.
