As the list of new import tariffs continues to grow, an advisory group is urging U.S. Customs and Border Protection to take actions to facilitate entries of imported goods that may be subject to multiple tariffs.
At a recent quarterly meeting of CBP’s Commercial Customs Operations Advisory Committee, COAC’s Antidumping and Countervailing Duty Working Group noted that when the Automated Commercial Environment was developed and programmed CBP selected an “edit light” approach in which duties for more complex entry summary lines (i.e., those with more than two HTSUS numbers) would not be calculated or validated by ACE. At the time, the working group said, this primarily affected sets, watches, ensembles, etc., and did not impact a materially large volume of entries.
However, “the volume of entries falling within the ‘edit light’ situation is expected to significantly increase due to the enactment and announcement of many more additional tariffs.” Examples include Section 232 tariffs on steel and aluminum and derivative articles; tariffs imposed under the International Emergency Economic Powers Act on imports from China, Canada, and Mexico; and potential Section 301 tariffs on imports from other countries following various unfair trade investigations. Further, the U.S. has continued to expand the range of goods subject to antidumping and/or countervailing duty orders, which have more than doubled in number over the last decade.
According to the working group, ACE’s inability to perform calculations or validations for entry summary lines subject to more than two types of import duties or tariffs “unnecessarily raises risks of noncompliance and additional expenses incurred by both trade and CBP.” For example, importers that run into such a situation and make an error in their entry summaries may have to file a prior disclosure or post-summary correction to fix it.
As a result, the working group recommended that CBP (1) alert the trade community that entry summary lines with more than two HTSUS numbers may require additional scrutiny prior to filing, (2) issue a CSMS message informing the trade community of any limitation within ACE on calculating or validating duties when more than two HTSUS numbers are reported on an entry summary line, and (3) program ACE to allow for the calculation of duties (estimated and liquidated) for entry summary lines that contain more than two HTSUS numbers and/or other trade remedy duties.
Separately, COAC’s Next Generation Facilitation Subcommittee recommended that the departments of Homeland Security and the Treasury approve CBP’s request for immediate funding for current ACE development to support anticipated new and future tariffs.
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