SEC 301 Lis#4 China Tariffs
The USTR announced the tariff list # 4 covering the remainder of goods not currently subject to additional 25% increase of tariffs. List#4 covers approximately $300 billion in imported goods from China.
The announcement with the full list of affected tariffs can be accessed here :
The Office of the U.S. Trade Representative (USTR) is seeking public comment and will hold a public hearing regarding this proposed modification.
DATES: To be assured of consideration, you must submit comments and responses in accordance with the following schedule:
- June 10, 2019: Due date for filing requests to appear and a summary of expected testimony at the public hearing.
- June 17, 2019: Due date for submission of written comments.
- June 17, 2019: The Section 301 Committee will convene a public hearing in the main hearing room of the U.S. International Trade Commission, 500 E Street SW Washington DC 20436 that begins at 9:30 a.m. Seven days after the last day of the public hearing: Due date for submission of post-hearing rebuttal comments.
For questions on customs classification, please contact http://traderemedy@cbp.dhs.gov
CONTINUOUS BOND SUFFICIENCY REVIEW
If you are importing from China at a high volume, you should conduct a thorough review of your continuous bond as it may saturate sooner due to the tariffs increase (from additional 10% to 25%).
U.S. CBP Revenue Division is conducting sufficiency review for all active continuous bond on a monthly basis and it is very critical to review and forecast your import activities to avoid bond insufficiency and bond stacking liabilities issue. When your continuous bond is rendered insufficient, there might be delays on clearing your cargo and the length of time to get your bond reinstated might take some time. Sureties may require collateral in a form of irrevocable letter of credit or cash to increase the bond based on several factors such as: commodities involved, duty margins and taxes, financial aspect, import history, etc.. The sureties may also require proof of financial stability by providing financial statements, tax returns and they will also need a signed General Agreement of Indemnity,
At Flegenheimer, we like to be pro-active in addressing this matter with our importers. It is in your best interest to understand your options and determine if a bond increase beyond minimum amount will be more appropriate.
To read more about “Customs Bonds”:
https://www.cbp.gov/trade/priority-issues/revenue/bonds/bond-centralization-program
To view the current bond formulas:
https://www.avalonrisk.com/questnewsletter/news/bondformulas.pdf
ACH Account for Payment of Duties to U.S. CBP
As addressed in our last E-Blast, we understand how these additional tariffs may significantly affect you and your cashflow. We suggest that you apply for an ACH account with U.S. Customs for payments of your duties in order to streamline your accounting process as Flegenheimer International will not be able to advance payment of these high duties on your behalf without receiving your payment beforehand. This is not a new procedure but we just wanted to make sure you are aware of our company policy.
Some of the benefits include:
- Payment of duties and fees on a monthly basis (PMS);
- Ability to pay duties for goods that are released during a given month as late as the 15th working day of the following month, providing additional flexibility in the management of the working capital as well as potentially significant cash flow advantages;
- Ability to pay designated entry summaries for a given month on one statement;
And more…
If you are interested, please send an e-mail to: info@flegenheimer.com
To learn more:
https://www.cbp.gov/document/guidance/periodic-monthly-statement