How would you check whether the latest Section 301 update affects your SKUs?
CBP's September 22 bulletin covers some revised exclusions. What's a sensible first pass before asking the broker to review old entries?
All questionsTariffs
9 replies
- I'd start with the exact exclusion descriptions and your product specifications. Matching a tariff number alone doesn't prove that a product meets the exclusion wording.
- Pull the affected entry lines with dates, classifications and duty amounts into one file. That gives the broker something concrete to review instead of a folder of invoices. Add a column for the product evidence and another for the review outcome. Then 'possibly affected' doesn't get confused with 'eligible and ready to file', which is the distinction finance will care about when the list starts circulating.
- The bulletin concerns four conforming amendments, not a general cancellation of China duties. I'd make that distinction clear before anyone books an expected refund.
- Keep the old and new statistical numbers side by side. A code change can otherwise look like a different product in your records.
- Ask the broker to flag the filing route and deadline for each candidate entry. Some may need a different process depending on where they are in their lifecycle.
- I would separate possible recovery from confirmed eligibility. Finance can see the opportunity without treating it as cash already in the bank.
- Save the technical evidence used for the match. If the product description is vague, get clarification from the manufacturer before submitting a claim.
- One person should own the candidate list. Otherwise purchasing, finance and two brokers can each create a slightly different version of the same review.
- For a small importer, starting with the highest-duty candidates makes sense. Just don't let the lower-value entries fall past a deadline while you're working through the big ones.
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