Nearly 100 items have lost their previous exemption status from China 301 tariffs. The sudden loss of exemption status for these products went into effect on July 9.
As a result, the previous 25% duties that were imposed on these products has been put back in place in addition to the normal duties that apply to their particular tariff numbers.
The administration's decision to not extend the exemption for these items came with short notice. However, the fact that an extension was not announced at least a few weeks earlier has been seen by many as a clue that this outcome could occur.
Given the current political climate between the US and China, it may come as no surprise that shippers may see similar actions take place in the future. Given the disruption that this can cause for shippers and their customers, we are hopeful that the trade community will receive more advance notice in order to ensure that entries are processed before the expiration dates occur.
Exclusions Expiring
The tariff exclusions granted in July 2019 for the following items are not being extended and will therefore expire July 9, at which point the 25 percent additional tariff will again be imposed on these goods.
- heat exchangers, the foregoing comprising parts of goods of heading 8402 and each fitted for heat recovery steam generator (described in HTSUS 8402.90.0010)
- drums, exhaust stacks, and inlet duct panel assemblies of heat recovery steam generators (described in HTSUS 8402.90.0090)
- water tanks for steam or other vapor generating boilers (described in HTSUS 8402.90.0090)
- compression-ignition engines with maximum power exceeding 50 kW but not exceeding 120 kW, each valued over $6,000 but not over $9,500 per unit (described in HTSUS 8408.90.9010)
- compression-ignition engines, exceeding 149.2 kW but not exceeding 373 kW and valued over $9,800 but not over $12,000 (described in HTSUS 8408.90.9020)
- aircraft gas turbine compressor cases of steel and Inconel alloy, each valued over $3,000 but not over $4,000 (described in HTSUS 8411.99.9090)
- engine stationary seal air supports of Inconel alloy, each measuring over 35 cm but not over 35.5 cm in outer diameter and over 3.5 cm but not over 4 cm in width (described in HTSUS 8411.99.9090)
- spring-operated motors, each valued over $3,000 but not over $3,600 (described in HTSUS 8412.80.1000)
- gear-type hydraulic fluid power pumps, handheld, battery powered, the foregoing not over 5 cm in width and valued not over $6 per unit (described in HTSUS 8413.60.0030)
- centrifugal water pumps incorporating thermal cut-offs, each with discharge outlet 5.08 cm or more in diameter, valued over $66 but not over $72 per unit (described in HTSUS 8413.70.2015)
- motor vehicle oil pump housings (described in HTSUS 8413.91.9010)
- impellers (described in HTSUS 8413.91.9095)
- parts of oil and gas extraction beam pumps, other than hydraulic power pumps (described in HTSUS 8413.91.9095)
- pedestals of pump assemblies (described in HTSUS 8413.91.9095)
- pump bases, of plastic, designed to protect the pump impellers from obstructions (described in HTSUS 8413.91.9095)
- pump expellers (described in HTSUS 8413.91.9095)
- pump grease cups and grease cup adapters (described in HTSUS 8413.91.9095)
- pump liners (described in HTSUS 8413.91.9095)
- pump manifolds (described in HTSUS 8413.91.9095)
- pump shaft castings, of steel (described in HTSUS 8413.91.9095)
- pump throatbushes (described in HTSUS 8413.91.9095)
- pump volutes (described in HTSUS 8413.91.9095)
- structural pump bases, of stainless steel (described in HTSUS 8413.91.9095)
- compressors, other than screw type, of a kind used in household refrigerators, air conditioners and heat pumps, rated at more than 1/4 horsepower but not more than 1 horsepower, each valued not over $150 (described in HTSUS 8414.30.8050)
- fork-lift trucks, propane gas powered, having a rated lift capacity over 9.5 metric tons but not exceeding 33 metric tons (described in HTSUS 8427.20.8090)
- motor grader weighing more than 14 metric tons but not over 21 metric tons (described in HTSUS 8429.20.0000)
- self-propelled pneumatic compactors, each weighing over 14 metric tons but not over 28 metric tons (described in HTSUS 8429.40.0040)
- new articulated shovel loaders, wheeled, each with 4-wheel drive, rear mounted engine and a bucket capacity of under 1.5 m3, rated at not over 26 horsepower (described in HTSUS 8429.51.1015)
- integrated tractor shovel loaders, each with 4 wheel drive, a bucket capacity of at least 3.8 m3 but less than 5.2 m3 and an operating weight of 17.5 metric tons or more but not over 20 metric tons (described in HTSUS 8429.51.1040)
- shovel loaders with an operating weight of from 30 metric tons to 36 metric tons (described in HTSUS 8429.51.1045)
- shovel loaders with an operating weight of from 30 metric tons to 36 metric tons (described in HTSUS 8429.51.1050)
- rubber track shovel loaders having a lift capacity not over 375 kg (described in HTSUS 8429.51.5010)
- grooved wire rope drum valued over $350 (described in HTSUS 8431.10.0010)
- escalator drive assemblies consisting of a motor, planetary gear, and gearbox (described in HTSUS 8431.31.0040)
- escalator steps (described in HTSUS 8431.31.0040)
- parts of passenger or freight elevators consisting of any of the following: elevator emergency brake and speed governor apparatus, scissor lift assemblies, telescoping boom lift assemblies, or articulating boom lift assemblies (described in HTSUS 8431.31.0060)
- counterweights for log handling equipment (described in HTSUS 8431.39.0070)
- backhoe counterweights each weighing more than 400 kg but not more than 600 kg (described in HTSUS 8431.49.9044)
- excavator crawler shoes (described in HTSUS 8431.49.9044)
- seeder or spreader baffle and baffle assemblies (described in HTSUS 8432.90.0060)
- seeder or spreader frames (described in HTSUS 8432.90.0060)
- seeder or spreader handles (described in HTSUS 8432.90.0060)
- seeder or spreader hopper assemblies (described in HTSUS 8432.90.0060)
- seeder or spreader hopper grates (described in HTSUS 8432.90.0060)
- seeder or spreader impellers (described in HTSUS 8432.90.0060)
- chipper/shredder machines, electrically powered (described in HTSUS 8436.80.0090)
- chipper/shredder machines, gasoline powered, valued less than $250 per unit (described in HTSUS 8436.80.0090)
- malt production equipment (described in HTSUS 8436.80.0090)
- horizontal lathes, electrically powered not over 1.5 horsepower (described in HTSUS 8458.19.0020)
- feeder and vibratory flow equipment and parts thereof designed for use in screening or sorting machines; housings and noise reduction enclosures; the foregoing described in HTSUS 8474.90.0010
- press machines for bamboo or other materials of a woody nature (described in HTSUS 8479.30.0000)
- electric wire coil-winder machines (described in HTSUS 8479.81.0000)
- insulated mixing chambers of stainless steel, each having a capacity of 5 m3 to 25 cubic meters (described in HTSUS 8479.82.0040)
- check valves of steel having an internal diameter not less than 4.8 cm or exceeding 62.5 cm (described in HTSUS 8481.30.2090)
- bodies of pressure-reducing valves other than hand-operated or check valves and valves classified in 8481.20, such bodies of brass (described in HTSUS 8481.90.9060)
- bodies of valves other than hand-operated or check valves and valves classified in 8481.20, such bodies measuring over 18 cm but not exceeding 19 cm in length, valued over $55 but not over $65 per unit (described in HTSUS 8481.90.9060)
- flanged wheel hub bearing units with ball bearings, each having an inner diameter exceeding 2.2 cm but not exceeding 2.8 cm (described in HTSUS 8482.10.5016)
- wheel hub angular contact bearing units, not flanged, valued over $2 but not over $10 per unit (described in HTSUS 8482.10.5024)
- inner bearing rings (described in HTSUS 8482.99.0500)
- non-toothed gears for office printers, each valued not over $7 (described in HTSUS 8483.40.9000)
- non-grooved pulleys, each incorporating a deep groove roller bearing (described in HTSUS 8483.50.9080)
- non-grooved pulleys, zinc plated, each valued not over $3 (described in HTSUS 8483.50.9080)
- hubs for conveyor pulleys with an outside diameter of more than 5 cm but not more than 56 cm (described in HTSUS 8483.90.8080)
- handles for machinery (described in HTSUS 8487.90.0080)
- electric motors of a width exceeding 7.5 cm but not exceeding 7.8 cm (described in HTSUS 8501.10.4060)
- DC motors, each valued over $125, with attached stranded copper cord (described in HTSUS 8501.31.2000)
- AC motors, multi-phase, each of an output exceeding 75 kW but less than 149.2 kW (described in HTSUS 8501.53.4080)
- AC generators, each weighing over 250 kg but not more than 1 metric ton and valued not over $2,400 (described in HTSUS 8501.62.0000)
- transformers designed to control horizontal motion of electron beams in cathode-ray tubes (described in HTSUS 8504.33.0020)
- static converter covers, bases and housings (described in HTSUS 8504.90.9650)
- furnace casings (described in HTSUS 8514.90.8000)
- manually operated rework stations, including soldering/desoldering stations (described in HTSUS 8515.19.0000)
- machines and apparatus for arc (including plasma arc) welding, each valued not over $500 (described in HTSUS 8515.39.0020)
- handheld transceivers (except citizen's band and except low-power radiotelephonic operating on frequencies from 49.82 MHz to 49.90 MHz), valued not over $70 each (described in HTSUS 8525.60.1030)
- fixed capacitors valued not over $4 per unit (described in HTSUS 8532.10.0000)
- fixed oil-filled capacitors rated at 1 kV to 25 kV (described in HTSUS 8532.10.0000)
- tantalum capacitors having a conductive polymer cathode, valued not over $4 per unit (described in HTSUS 8532.21.0050)
- tantalum capacitors, each measuring 7.3 mm by 4.3 mm by 1.9 mm and valued not over $4 (described in HTSUS 8532.21.0050)
- contactors, for a voltage not exceeding 60 V and with contacts rated at or more than 10 A, each valued not over $18 (described in HTSUS 8536.41.0045)
- momentary contact switches rated at or under 5 A, each designed for use as a motor vehicle overdrive switch (described in HTSUS 8536.50.9031)
- momentary contact switches rated at or under 5 A, valued not over $4 per unit (described in HTSUS 8536.50.9031)
- rocker switches, for a voltage not exceeding 1,000 V, designed for use in motor vehicles (described in HTSUS 8536.50.9065)
- molded buttons (described in HTSUS 8538.90.6000)
- molded housings and covers (described in HTSUS 8538.90.6000)
- tanks for dead tank circuit breakers, of aluminum (described in HTSUS 8538.90.8120)
- aluminum anodes for use with machines and apparatus for electroplating, electrolysis or electrophoresis (described in HTSUS 8543.30.9080)
- chlorine generator chambers containing titanium plates for use with machines and apparatus for electroplating, electrolysis, or electrophoresis (described in HTSUS 8543.30.9080)
- veterinary ultrasound device with black-and-white image quality used as a medical diagnostic tool (described in HTSUS 9018.12.0000)
- microwave ablation antennas, whether or not with attached controls, as parts of ablation systems used to ablate live tumors (described in HTSUS 9018.90.6000)
- parts and accessories of electro-surgical instruments and appliances, other than extracorporeal shock wave lithotripters (described in HTSUS 9018.90.6000)
- smoke evacuation pencils with accompanying tubing and hoses designed to integrate smoke evacuation into electrosurgery by combining both features into a single handpiece, which is designed to apply mono-polar electrosurgical energy to target tissue in a surgical setting while simultaneously evacuating smoke from the surgical site (described in HTSUS 9018.90.6000)
- suction coagulators, consisting of a handpiece with mechanical and/or electrical controls and a disposable shaft, used for the coagulation of tissue and aspiration of fluids during surgical procedures (described in HTSUS 9018.90.6000)
- vessel sealing and dividing devices that use electrical energy to separate and seal tissue during open or laparoscopic surgical procedures, consisting of a handpiece with mechanical and/or electrical controls, and a bipolar electrode intended to deliver electrosurgical current from a system generator directly to tissues for cutting/coagulation/ablation (described in HTSUS 9018.90.6000)
- dental X-ray alignment and positioning apparatus, each valued over $5,000 (described in HTSUS 9022.90.6000)
- overhead tube suspension used to hold and position X-ray generating equipment (described in HTSUS 9022.90.6000)
- instruments and apparatus that chemically analyze food to detect the presence of gluten or peanuts, valued at less than $55 per unit (described in HTSUS 9027.80.4530)
- picoammeters with recording devices (described in HTSUS 9030.39.0100)
- humidistats, each with outdoor sensor, such humidistats valued not over $40 each (described in HTSUS 9032.89.6070)
© 2020, Sandler, Travis & Rosenberg, P.A., Reprinted by permission.
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