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PESA Tariffs Exclusion Process

Dear Members,

As you know, PESA was successful in obtaining several products temporarily excluded from the Section 301 duties on Chinese goods. These exclusions are scheduled to expire in the coming months on a varying timetable. Prior to their expiration, interested parties have the opportunity to file comments in support of extending the exclusion for an additional year. While there is no guarantee that the government will agree to extend, if your company is benefiting from one or more exclusions, it is worth considering whether to submit a comment.

PESA has engaged trade attorneys to help submit comments. The process is detailed and will need to include much of the information that was needed for the original exclusion. If your company is currently declaring one or more Section 301 exclusions and is interested in getting that exclusion extended for an additional year, please respond to this email with the following:

(i) a list of the Section 301 exclusions that your company is declaring; and

(ii) a sample import entry summary (Form 7501) that corresponds to each exclusion listed in (i).

If interested, please reply to this email with the requested information by March 20, 2020. The more company data that we receive will make the application for the exclusion extension stronger. As PESA will undertake legal costs for this endeavor, there will be a single fee per company for the application.

The three exclusions that will be up first are USTR-2018-0025-6589 (Reciprocating Positive Displacement Pumps), USTR-2018-0025-6591 (Cylindrical Pumps) and USTR-2018-0025-6602 (Carbon and Steel Machined Pump Components). However, the full batch of PESA exclusions (links below) will be up soon as well, so please include all that your company is using if you wish to participate in the process. Exclusions “extend for one year after the exclusion notice is published in the Federal Register.”

Should you have any questions, or would like to share information. Please contact Vice President Government Affairs Tim Tarpley.

HTS 8413702090 – Cylindrical Pumps (granted May 29, 2019, published June 4, 2019)
HTS 8413500010 – Reciprocating Positive Displacement Pumps (granted May 29, 2019, published June 4, 2019)
HTS 8413919080 – Beam Pumping Units (granted July 3, 2019; published July 9, 2019amended in February 2020
HTS 8413919080 – Hollow Steel Rods (granted September 17, 2019; published July 9, 2019amended in February 2020
HTS 8421990080 – Carbon and Steel Machined Pump Components (granted September 17, 2019; published June 4, 2019)
HTS 8413919080 – Pump Castings (granted July 3, 2019; published July 9, 2019amended in February 2020