CBP Still Considering 'Operational Approach' to Implementing Hong Kong EO

CBP “is evaluating” the “operational approach to implementing the President’s direction” in light of the executive order ending Hong Kong's special trade status (see 2007150054), a CBP spokesperson emailed July 16. “The EO instructs agencies to commence appropriate actions within 15 days,” the spokesperson said. “We’ll be able to share more information soon.”

The EO “paves the way for Hong Kong-origin goods to be subject to additional duties imposed on articles of China under Section 301,” Sidley Austin lawyer Ted Murphy said in a blog post. But the EO also doesn't specifically address the Section 301 tariffs and “the only direct reference to US customs regulations is the mention of 19 USC 1304 marking regulations,” Geodis said in an email. “We expect that CBP or other federal agencies will issue instructions on the impact to trade-remedy coverage, country of origin determinations (in addition to the marking), [Manufacturing ID] reporting, invoice requirements, and related impacts,” the company said.