On March 20, 2020, the United States Trade Representative (“USTR”) issued new product exclusions pertaining to the 25% Section 301 List 3 Tariffs.  The new list of exclusions includes one 10-digit HTS subheading that covers one exclusion request and 176 specially prepared product descriptions that cover 202 separate exclusion requests.  The full list of excluded products is available here.  According to the USTR, the product exclusions apply retroactively to entries going back to September 24, 2018 and remain in effect until August 7, 2020.  The products affected include auto parts, printed circuit boards, and certain seeds for planting.

The USTR is also seeking comments on the possible exemption of medical goods from the Section 301 tariffs in response to the COVID-19 epidemic. The USTR stated that “each comment specifically must identify the particular product of concern and explain precisely how the product relates to the response to the COVID-19 outbreak.” According to USTR, the docket for submitting comments will remain open until at least June 25, 2020, with the possibility of that deadline being extended.

We encourage clients and companies to review the listed exclusions and USTR’s notice on COVID-19 exclusions and contact Husch Blackwell’s International Trade and Supply Chain Team with any questions or concerns.