On June 8, 2020, the U.S. Trade Representative (USTR) announced thirty-four (34) new China Section 301 List 4A product exclusions. These new product exclusions are set forth in two (2) ten-digit HTSUS classifications covering certain unbleached woven fabrics of cotton and thirty-two (32) new product-specific descriptions covering a variety of goods such as certain duck or geese down, cyanuric chloride, plastic kneeling pads, plastic mop fittings, Chinese language books, gloves, pillow and comforter shells, steel round wire, loose leaf ring binders, brass valves, lithium-ion batteries, optical channel splitters, LCD main board assemblies and modules, plastic safety spectacles, wristwatch parts, child safety seat parts, fish hooks, mope heads, swine hair bristles, and electrical spark lighters. These China Section 301 List 4A product exclusions are retroactive to September 1, 2019 and expire on September 1, 2020. Note the very limited effective date for upcoming shipments.
The product exclusions from the China Section 301 duties are available for any importer for any product that falls within the special product descriptions and enumerated ten-digit HTSUS classifications. This is true regardless of whether the importer filed the initial product exclusion request. Clients may also benefit by filing Post-Summary Corrections (PSCs) or Protests for those entries now covered by a List 4A product exclusion to secure refunds plus interest. Unless liquidation extensions are granted, Protests may be required for liquidated entries. It is important to identify affected entries and filing deadlines. The refund process is complicated and should be carefully considered.
Clients may contact Ryan Thornton to obtain an updated version of the comprehensive spreadsheet we have prepared of all product exclusions from China Section 301 duties to date.