Background

Many petitions seeking import tariff suspensions or reductions under the miscellaneous trade bill process have deficient article descriptions and are in danger of being rejected, according to the International Trade Commission. If these deficiencies are not addressed through the submission of revised petitions before the Dec. 12 deadline, the requested duty relief will not be granted.

The ITC says it does not have the resources to notify all petitioners whose filings are deficient, particularly if there is a surge in the number of petitions late in the filing period. The ITC has alerted some petitioners of potential deficiencies but is under no obligation to do so.

It is, therefore, critical for all MTB petitions to include article descriptions that:

(1) use language that is clear and administrable by U.S. Customs and Border Protection;

(2) include all applicable HTSUS subheadings; and

(3) include any standard identification numbers or names.

MTB petitions (including those revised to address deficiencies) that are filed on or after Dec. 13 or are filed improperly will have to wait until October 2019 for another opportunity to be considered.

If you have already submitted an MTB petition, we recommend an immediate review prior to the Dec. 12 deadline.

For assistance in crafting or reviewing an MTB petition to meet required standards, please contact Larry Ordet at (305) 894-1003 or David Olave at (202) 730-4960.

Professional

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David F. Olave
Associate & Trade Policy Advisor
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Larry T. Ordet
Member
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