Section 301 European Imports

Are you importing from Europe or UK?
It’s time to submit your comments.

The United States Trade Representative (USTR) is requesting comments on the consideration of modifying Section 301 tariffs imposed on imports from certain European member states and/or the United Kingdom associated with the Large Civil Aircraft dispute. These modifications would be in addition to the current list of commodities subject to Section 301. Additional tariffs could reach up to 100 percent, therefore, we highly suggest reviewing the lists in each of the Annexes.

If you are importing any of the items on the lists from a European Union member state or the United Kingdom, we recommend you submit your comments as soon as possible. The electronic portal for submitting comments will open on June 26, 2020 and expire on July 26, 2020.

The Lists

Annex 1 – contains the list of products currently subject to additional duties of 15 or 25%.

Annex 2 – contains a list of products not currently subject to additional duties, but under consideration. This list contains products of current or former EU member States for which additional duties of up to 100 percent previously were proposed, but for which no additional duties currently are imposed.

Annex 3 – contains a new list of products under consideration from France, Germany, Spain, and the United Kingdom. Ad valorem duties on this list could reach 100 percent. This list of products contains 30 tariff
subheadings with an approximate value of $3.1 billion in terms of the estimated import trade value for calendar year 2018.

A final list of products subject to additional duties in the action may be drawn from the list of products in Annexes I, II, or III.

What the USTR is considering:

  1. Whether or not products listed in Annex I should be removed from the list or remain on the list
  2. Whether or not the rate of additional duty on specific products should be increased, up to a level of 100 percent
  3. Whether or not additional duties should be imposed on specific products listed in Annex II or Annex III
  4. On the rate of additional duty of up to 100 percent to be applied to any products drawn from Annex II or Annex III

How to Submit Comments

  • Go to USTR Comment portal: or click here.
  • Docket is entitled “Comments Concerning the Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute”
  • You do not need to establish an account to submit comments
  • You can comment on multiple products in a single entry, or submit multiple comments

What to do

There are a number of things you can do.  Scarbrough Consulting, Inc. is offering a free 30-minute consultation to any company that may be affected by the Section 301 announcements.  Please send an email to or fill out the form below.  Our Global Trade Experts and Licensed Customs brokers are here to help optimize your supply chain and add to your bottom line.

Want to Recover Duty paid to CBP?

Duty Drawback is allowed on Section 301 products.  Ask our team for more information if you are using any Section 301 components to produce items that are re-exported out of the USA.  There are other ways to save money on duty.  Check out our recorded Duty Savings Opportunities Q&A Session.

About Scarbrough

The Scarbrough Group of Companies, headquartered in Kansas City with local presence in every major port in the world, is a complete international and domestic supply chain service provider, offering U.S., Mexican, and Canadian Customs brokerage, Import & Export Transportation Solutions, Domestic brokerage and asset-based trucking, Warehouse fulfillment and distribution services, Trade Compliance Consulting, Large Equipment and Project Cargo moves, as well as Parcel Audit Savings.  Scarbrough is widely known for its trade experts, training, personalized customer service, and customized solutions.  Since 1984, Scarbrough has continued to satisfy its clients by following its motto on a daily basis: “It is our job to make your job easier.”  Moreover, our team of experts is available at your disposal.  We offer free consultations on any topic from supply chain optimization and duty savings opportunities to the basics, helping to guide new importers and exporters as they jump into the world of global trade.  Contact us now.