MEMO TO CLIENTS ISSUE 19-004 – February 25, 2019

President Trump Announces Postponement of Section 301 Tariff Increase
In a tweet on Sunday, February 24, President Trump said that he will again delay the Section 301 tariff increases, which were due to go into effect on
March 2. This announcement pertains to the Tranche 3 list of HTS numbers that will be increasing from 10% to 25%. The postponement of the increase is a result of “substantial progress in the trade talks with china on important structural issues including intellectual property protection,
technology transfers, agriculture, service, currency and many other issues.” The President plans to meet with President Xi Jinping to work on a final
deal, but the date of that meeting has not been set yet. The length of the postponement was not announced on Sunday. President Trump will issue
instructions to the U.S. Trade Representative (USTR) and a formal announcement detailing the timeframes is expected sometime this week. We will check the USTR’s website regularly and send the announcement as soon as it is issued. TSCA Certification Requirements for Composite Wood Products Available Soon U.S. Customs and Border Protection (CBP) will
finally update its list of required data elements for entry of goods subject to the Toxic Substances Control Act (TSCA) requirement for Composite Wood Products. CBP has said that there will be over 450 HTS numbers flagged for the TSCA certification requirements. In an effort to prepare for the transition, CBP will host two webinars that will help trade professionals understand the requirements of TSCA import certification. The first webinar will be held on Tuesday, February 26 from 2-3 pm EST. Registration is available on CBP’s website.

New CBP Form 5106 Goes Into Effect March 16
CBP Form 5106 is the form that U.S. Customs and
Border Protection (CBP) uses to place an importer
in their computer system by their importer of
record (IOR) number. The IOR number can be an
importer’s federal tax identification number, a
social security number, or a CBP assigned number.
The current form is used to identify the importer,
the importer’s current mailing address and their
physical location. The new 5106 form will ask for
much more detail about the importer and its
responsible party. Although many of the boxes on
the new form are not mandatory for every
importer, CBP has said that the details it receives
on the form will be used as part of an importer’s
risk management review.
Importers that are already on file in CBP’s system
will not be required to be complete the new 5106
form. However, certain common actions such as
new bond applications, formal name changes or
any changes to an importer’s address, will require
importers to complete and submit the new form.
Importers should take a look at this document to
be aware of what CBP is looking for.
A draft of the new form can be found on CBP’s