2020 outpaced even the active 2019 in terms of the frequency of Harmonized Tariff Schedule updates. Most of the updates implemented new Section 301 exclusions and changes and extensions for existing ones. Other major changes included new Section 232 tariffs on steel and aluminum "derivatives" and the withdrawal of Generalized System of Preferences benefits for many goods from Thailand In all, 13 revisions were issued prior to the mid-year Revision 14, as follows:

CBP published several thousand prospective rulings in 2019 on its Customs Rulings Online Search System (CROSS) database. The agency issues its rulings from either the National Commodity Specialist Division in New York, which handles issues like classification, country of origin, marking and preferential treatment, or the Office of Regulations and Rulings at CBP headquarters in Washington, D.C., which may also decide other issues, such as valuation, drawback, exclusion order enforcement and liquidation.

The following is a selection of articles that appeared in International Trade Today in 2019 covering ruling letters. CBP frequently publishes rulings months after they are issued, so these articles are included based on the dates the articles were published, rather than the date the ruling letter was issued.

CBP published notices in the Customs Bulletin revoking or modifying numerous rulings in 2019. These ruling revocations and modifications also apply to “any treatment previously accorded by CBP to substantially identical transactions.” When revoking or modifying a ruling, CBP is required by 19 USC 1625(c) to publish notice of the proposed action, and allow a period—generally one month—for comment before finalizing the action. An importer’s failure to advise CBP of “substantially identical transactions” or of a ruling not identified by CBP in these notices “may raise issues of reasonable care on the part of the importer or its agents for importations of merchandise subsequent to the effective date of this notice.” Rulings CBP revoked or modified in 2019 are as follows:

The International Trade Commission posted the 2020 Basic Edition of the Harmonized Tariff Schedule. The new HTS implements the U.S.-Japan trade deal that took effect Jan. 1, as well as changes to eligibility for African Growth and Opportunity Act benefits. Changes to units of quantity are also made to the tariff schedule, resulting in the complete elimination of UOQ "X" from the tariff schedule (except for in Schedule B), and new statistical breakouts are added in chapters 17, 38, 72, 76, 83, 84, 85 and 87. The changes took effect Jan. 1.

The final set of tariff reductions under the Expanded World Trade Organization Information Technology Agreement will take effect July 1. International Trade Today is again providing a table of changes to tariffs in the Harmonized Tariff Schedule for certain products as a result of this last round of implementation. While tariffs on many products were eliminated completely when the agreement took effect in July 2016, other products subject to the expanded ITA have seen tariffs phased out over a three-year period, with tariffs for all remaining products covered by the agreement now reduced to zero in 2019.

2019 is shaping up to be another active year in terms of changes to the Harmonized Tariff Schedule. Like last year, a series of revisions were necessary in the first half of the year to implement Section 301 exemptions and an increase for $200 billion worth of the China tariffs from 10 percent to 25 percent. Other major changes are related to the Generalized System of Preferences, and in particular the removal of India and Turkey from the program. In all, seven revisions were issued prior to the mid-year Revision 8, as follows:

The International Trade Commission on July 1 posted Revision 8 to the 2019 Harmonized Tariff Schedule. The semiannual update to the HTS implements the fourth and final round of tariff cuts under the expanded World Trade Organization Information Technology Agreement. It also extensively reorganizes 10-digit tariff subheadings covering aluminum products, and adds tariff provisions for aerial work platform trucks, frozen berry mixes, diamond grinding wheels, storage lockers and certain electric motorcycles.

ITC Issues Semiannual Revision to 2019 HTS; Changes Take Effect July 1