The additional 10 percent tariff set to be imposed on hundreds of billions of dollars’ worth of products imported from China (List 4A goods) will be triggered by the date of entry. As a result, there will be no reprieve for such goods that are currently on the water but unable to reach the U.S. before Sept. 1. Importers thus have mere weeks to renegotiate prices with their vendors to minimize the impact of this tariff increase.

It is critical that importers properly document and execute any discounts or price reductions so they are incorporated into the value on which the additional tariff will be assessed. In particular, importers should ensure that (a) the discount or price adjustment is agreed prior to the importation of the goods and (b) related supporting documentation complies with U.S. Customs and Border Protection guidelines.

Sandler, Travis & Rosenberg P.A. can advise your business on how to comply with CBP rules and prepare the optimal Section 301 tariff mitigation strategies now. For more information, please contact Thomas Travis at (305) 894-1001 or Amanda Levitt at (212) 549-0148.

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