Per the below announcement, the U.S. International Trade Commission (USITC) has recommended that the President make certain modifications to the Harmonized Tariff Schedule of the United States (HTS) to conform it with World Customs Organization (WCO) amendments to the global Harmonized System.
While the changes to the HTS will not take effect until January 1, 2022, it is important to be prepared for these changes. Companies can review the Recommended Modifications in the Harmonized Tariff Schedule, 2021, Inv. No. 1205-13, USITC Publication 5171 to understand the potential changes. Appendices C and D include tables showing current HTS and recommended HTS.
- Develop a cross-functional review team – Some of these changes may require companies to revisit their HTS classifications. Some HTS numbers may split into two HTS numbers. You may need to work with your internal engineering/technical services colleagues as well as other functions to review HTS and relevant Section and Chapter notes. The final list of HTS changes will not be available until December 2021, so there will be not be much time to complete the review. Form your team now so you are ready to act quickly when the final changes are issued.
- Perform an impact analysis – Review the potential changes to the HTS to determine if any of the changes will impact your current HTS classifications. Some Customs brokers can take a list of part numbers with associated HTS and “bounce” it against the new HTS list. The resulting list will show all of the part numbers impacted by the HTS changes.
- Communications plan with customs broker – Companies will need to provide a part number list with new HTS numbers to their Customs brokers. This is especially important for companies which have many part numbers and a variety of HTS. Since your broker is working with many companies who are also making these updates, make sure you are providing the part number list with the new HTS to the customs broker on a timely basis. In addition, confirm with the broker that the list has been uploaded into their internal system and is ready to be utilized for import/export declarations.