Section 301 Refunds

With the end of the year fast approaching, Section 301 refunds are on the minds of the JUSDA Trade Compliance team.  Many American businesses could lose out on rightfully Section 301 drawbacks if they don’t act soon.  Data analysis on Section 301 China trade tariffs, which are eligible for exclusions, found that many American companies have not acted in securing approvals for exclusions written into the tariffs by the Trump administration and that the current tariff exclusions expire on Dec. 31st.  If companies have not applied for refunds for tariffs paid on an exempted product by then, they will lose out on the opportunity to claw that money back.

Since Spring, the office of the US Trade Representative has exempted some medical products from Section 301 tariffs in rounds of exclusions and more could be coming. But the exclusions don’t only apply to medical products; nearly 2/3rds of goods imported from China are potentially eligible for Section 301 tariff exclusion.

Organizations must first determine if the goods they are importing qualify for a tariff exclusion and then perform the time-consuming task of comparing the specific 301 exclusion to the HTS codes to find a match. JUSDA offers free access to its Section 301 online list tool to assist companies in looking up exclusions.  For companies that have already paid tariffs, refunds are possible. It can take 60 to 90 days or more, though, to receive that refund.