Julio Rodriguez US Customs BrokerSince 2007
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Section 301 refunds: what is really recoverable

The Section 301 China tariffs have been stacking onto import bills since 2018, and unlike the IEEPA tariffs they were not struck down. But recoverable money hides in two places, and importers walk past both.

Route one: exclusions

USTR has granted and periodically reinstated product-specific exclusions from the 301 lists. When an exclusion covers your product and its window covers your entry dates, the 301 duty on those entries is refundable: by PSC if the entry has not liquidated, by protest within 180 days if it has. The work is matching your ten-digit HTS numbers and product descriptions against the exclusion language, precisely; near misses do not pay.

Route two: drawback

Section 301 duties are drawback-eligible, confirmed by CBP in CSMS 18-000419. Import Chinese-origin goods, pay the 301 duty, later export the goods or their products, and up to 99 percent of that duty is claimable with a five-year lookback. For Miami's re-export trade to Latin America this is routinely the largest unclaimed refund on the books. The contrast to hold onto: Section 232 depends on the proclamation and on the entry date, and AD/CVD is always excluded. 301 is the special tariff that gives money back.

Tariff refunds

Paid IEEPA or Section 301 tariffs? Find out what you can get back.

Licensed customs brokers since 2007, filer code EWV. We file your refund under our own license: IEEPA claims through CAPE, protests, post-summary corrections and duty drawback. Priced per entry and quoted before you commit, with no percentage of your refund.

FAQ

Can I get Section 301 tariffs refunded?

In two situations: an exclusion covers your product and entry dates, claimed by PSC or protest, or you exported the goods and can claim drawback of up to 99 percent with a five-year lookback.

How do I know if my product has a 301 exclusion?

Exclusions are defined by HTS number plus a product description, and both must fit. We check your classifications against the current and reinstated exclusion lists as part of any 301 review.

Are Section 301 duties eligible for drawback?

Yes, per CSMS 18-000419. Section 232 depends on the proclamation, and AD/CVD duties never are. The three get confused constantly, and the confusion costs real refunds.

Do 301 refund claims have deadlines?

The same clocks as everything else: PSC before liquidation, protest within 180 days after, drawback within five years of importation. Which windows are open depends on your specific entries, which is where a broker's records check starts.

Get your 301 exposure reviewed

Send us your HTS numbers and lanes. A licensed broker will check exclusions and drawback eligibility against your actual entries.

Tell us about your shipment

A few lines is enough. A licensed customs broker reads every message, and a half-filled form is a completely normal way to start.

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Julio Rodriguez US Customs Broker is a licensed customs brokerage, established 2007, CBP filer code EWV, clearing freight at every port in Puerto Rico and the mainland United States from offices in Cataño, Puerto Rico and Orlando, Florida, with daily work in Miami, in English and Spanish.