Post Summary Corrections (PSC) for Section 301 Tariff Exclusions

Client

A global manufacturer of vacuum cleaners and floor care products with significant import volumes from Asia supporting U.S. manufacturing and distribution operations.

Challenge

Beginning in 2018, Section 301 tariffs were imposed on many Chinese-origin products, often at 25% additional duty, as part of the U.S. government’s response to intellectual property theft and unfair trade practices.

Because tariff exclusions were issued months after implementation, importers were required to pay the Section 301 tariffs at the time of entry while waiting to see if their specific products would ultimately qualify for an exclusion.

When exclusions were later granted for several of the client’s products, the company had already paid more than $70 million in Section 301 duties across thousands of import entries.

Their existing multinational customs broker confirmed that Post Summary Corrections (PSC) could be filed to recover the duties, but informed the client they would not be able to begin the project for approximately five months due to internal resource constraints.

The client approached J.M. Rodgers Co. to determine whether a broker that did not originally clear the cargo could take on the PSC project and manage the recovery process.

Solution

J.M. Rodgers confirmed that PSC filings can be performed by a broker other than the original filing broker and began by assessing the scope and complexity of the project.

Initial Project Assessment

JMR worked with the client to evaluate:

• Total number of entries requiring correction
• Eligibility for Section 301 exclusion treatment
• Complexity of the entries, including multiple line items per entry
• Documentation availability to support tariff exclusion claims

Project Implementation

To begin the project, JMR established a structured workflow with the client:

Getting Started

• Secured access to the client’s ACE account
• Obtained a comprehensive list of entry numbers for review
• Established a secure FTP site for document exchange

Required Documentation

• CBP Form 7501 Entry Summaries
• Commercial invoices
• Packing lists
• Air Waybills / Bills of Lading
• Product specifications and supporting documentation validating exclusion eligibility

Data Review and Analysis

JMR conducted a detailed analysis of entry-level import data to identify entries eligible for Post Summary Corrections related to Section 301 tariff exclusions.

Entry Categorization and Project Planning

Entries were categorized into appropriate tiers depending on the corrective action required, including:

• Entries eligible for straightforward PSC filings
• Entries requiring additional classification review
• Entries requiring supporting documentation verification

PSC Strategy Development

JMR developed a structured filing strategy based on:

• Regulatory requirements governing PSC filings
• The client’s entry data and exclusion eligibility
• Documentation supporting tariff exclusion claims

Preparation and Filing of PSCs

JMR prepared and submitted PSC filings through CBP systems for eligible entries, ensuring that corrections reflected the proper application of the Section 301 exclusion.

Project Coordination and Reporting

Throughout the project, JMR:

• Coordinated with the client to confirm documentation and eligibility
• Managed PSC submission timelines
• Provided regular progress updates and duty recovery estimates

Outcome

• 3,500+ entries reviewed and corrected
• Over $70 million in Section 301 tariffs addressed through PSC filings
• Entire project completed within four months
• Enabled the client to pursue duty recovery significantly faster than originally projected by their previous broker

Key Takeaways

• PSC filings allow importers to recover duties when tariff exclusions are issued after importation
• Brokers other than the original filing broker can manage PSC recovery projects
• Large-scale duty recovery projects require structured data analysis and compliance oversight
• Efficient project management and regulatory expertise can significantly accelerate duty recovery timelines