May 2019 Tariffs Update

May 16, 2019

With the imposition of a new tranche of tariffs on Chinese goods this past Friday, there is confusion in the market as to whether those tariffs apply to molds.  The tariffs did not change the exemption that currently apply to molds; injection molds remain exempt for tariffs until December 27, 2019.  All importers who have an eligible mold, are able to claim an exemption, even if the importer did not file for an exemption prior to the October 2018 exemption deadline. 

U.S. Customs and Border Protection (CBP) is also now accepting applications for refunds of tariffs paid on molds imported from China.  These refunds are obtained by an importer filing a Post-Summary Correction in the Automated Commercial Environment (ACE).  The process for seeking the refund via a Post-Summary Correction can be confusing, and is technical.  We strongly recommend you work with your customs broker or importer of your molds to submit the Post-Summary Correction since the importer or broker submitted the original paperwork with the mold.

CBP also states that when importing molds, importers and customs brokers should use HTSUS 9903.88.05 as the classification (in addition to the regular HTSUS classification of 8480.71.8045 for molds) to avoid tariffs being imposed on the molds for the remainder of 2019.  Please advise your importer or customs broker accordingly.

If you have any questions, feel free to reach out to Alan Rothenbuecher at Benesch (