While Sandler Trade LLC continues to work with the 21-nation Alliance of GSP Countries to advocate for prompt renewal of the GSP program, we would like to remind everyone that the petition deadlines for the 2013 Annual GSP Review are fast approaching.
USTR announced its process and deadlines in the Federal Register on July 29. Due Friday, October 4 (just 16 days from now!) are petitions for: 1) products to be added to GSP eligibility, 2) product removals, and 3) country practices (such as IPR, worker rights, investment). Petitions for Competitive Need Limitation (CNL) waivers are due on Friday, November 22, 2013.
Suppliers, importers, or countries that fail by November 22 to submit petitions to request CNL waivers for products exceeding the CNL thresholds in 2013 will lose GSP benefits. The only situation by which this would not be true is if GSP is renewed close to June 30, 2014, which would not leave enough time for the required analyses. U.S. importers and foreign producers need to pay close attention to these deadlines – especially for the CNL waivers – and file their petitions accordingly.
As always, Sandler Trade LLC is here to assist you! If we may briefly pat ourselves on the back — Sandler Trade LLC is proud that our efforts helped secure the approval of the only CNL waiver granted during the 2012 Annual GSP Review – more on that below.
As announced by USTR, products imported from GSP-eligible countries will be excluded from GSP duty-free treatment effective on July 1, 2014 for U.S. imports that meet one of the following two CNL criteria, unless CNL waiver petitions are submitted and granted:
1) 2013 imports for a product under an 8-digit GSP-eligible tariff line from a country have reached 50% of overall U.S. imports for that tariff line, and total U.S. imports of that tariff line exceeded $21.5 million; and
2) 2013 imports for a product under an 8-digit GSP-eligible tariff line from a country exceeded $160 million.
USTR also announced that, due on Friday, October 4, 2013, are petitions to modify the list of articles eligible for GSP treatment, as well as petitions to review the GSP status of beneficiary developing countries. Companies or beneficiary countries that would like to add products to the GSP-eligible products list need to start preparing their petitions.
We help clients achieve success in GSP Reviews – cost-effectively!
Under the 2012 GSP Annual Review, our firm helped JMC (USA) – Bozel North American Division (Bozel) and Polymet Alloys, Inc. (Polymet) petition, through a series of written and oral submissions, to retain duty-free treatment for U.S. imports of calcium silicon ferroalloy (CaSi) imports from Brazil that had exceeded the CNL thresholds. The petition was approved, and CaSi imports from Brazil remain eligible for GSP treatment and the 5% import duty savings. We could not be more proud of this accomplishment, and we are pleased that U.S. importers and CaSi users, as well as Brazilian producers were able to use GSP to strengthen their competitiveness and realize savings.
The petition deadlines for the 2013 GSP Annual Review are fast approaching!
We look forward to assisting other companies that require CNL waivers or want to petition for product additions to meet with similar success. It is not too late to discuss adding a product to the list of GSP-eligible items. If you would like to know if a crucial product you are importing may require a CNL waiver, or require cost-effective assistance with preparing a petition, please contact Sandler Trade LLC for an exploratory conversation.