The USTR this afternoon published the finalized list for Trump’s 3rd round of tariffs on products from China. The original list had 6031 tariff subheadings. The final list contains roughly 5745 tariff subheadings. I highly recommend that importers take a close look at the tariff list to review which of their products may be impacted. Please note the following important points:

• The tariff will be effective September 24, 2018. For importers who have products in transit, please note that if your shipment arrives on or after September 24, 2018, your shipment will be subject to the new tariff. This applies regardless whether the Customs Broker submits the entry prior to September 24, 2018. If the actual vessel / aircraft does not arrive until September 24, 2018 or after, the shipment will be subject to the tariff.
• The initial rate of the tariff will be 10%. Starting January 1, 2019, the tariff will increase to 25%.
• Please note the finalized list is divided into TWO parts. The first part contains the main part of the list. However it is very important that readers also look at the second part which is on the last two pages of the list. The last two pages carve out some exceptions for a few select products. Please read it very carefully. We also think there may be a typographical error in regards to the exceptions listed under 8517.62.00 as 8517.62.0090 currently does not exist in the tariff schedule. The tariff schedule itself may be changed, so we are waiting to see if this is a clerical error or not.
• The USTR just announced procedures for requesting exclusions for products under List#2. The deadline for exclusion requests for products under List#2 is December 18, 2018. The list #2 tariffs went into The USTR has not yet announced procedures for requesting exclusion for products under List#3 yet. We expect some announcement of instructions in the near future.

Please note that China has threatened to retaliate, as they have done so with the first two tariff lists. Trump has in indicated he has a 4th list ready to enact should China retaliate in response to this third list.