On March 23, 2022, the U.S. Trade Representative (USTR) announced the reinstatement of 352 of the 549 eligible exclusions, most of which expired on December 31, 2020. It is important to note that this reinstatement is retroactive to October 12, 2021, and the new exclusions will be in effect for entries through December 31, 2022. These reinstated exclusions will be covered by a new subheading 9903.88.67. A copy of the complete notice which lists the HTS numbers and the products covered in the reinstatement can be found here.

CBP has not yet provided guidance on the method to retroactively seek refunds, but we suspect they will maintain the same procedures as before, filing Post Summary Corrections (PSC) for unliquidated entries, and filing Protests for liquidated entries.

V. Alexander will continue to monitor this situation as it develops and issue updates accordingly.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics.

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