10/02/2026
United States and China Launch "30-for-30" Trade Framework
Check out this week's Customs Corner to read about United States and China Launch "30-for-30" Trade Framework, Technical Corrections to Section 232 Duties on Pharmaceutical Imports, and more!
Trade and Customs Updates
United States and China Launch "30-for-30" Trade Framework
The United States and China have reached an understanding to operationalize the "30-for-30" framework through the newly established U.S.-China Board of Trade. This initiative marks a pivotal step in enhancing bilateral economic relations between the two nations.
Previously agreed upon by both countries, the U.S.-China Board of Trade aims to foster government-to-government dialogue focused on reducing tariff barriers. The initial focus of this board is a dialogue centered around lists of mutually agreed-upon imported goods, each valued at approximately $30 billion. The objective is to provide reciprocal reduced tariff treatment for these goods.
Officials from both nations have spearheaded the development of proposed product lists for inclusion in the "30-for-30" framework. These lists consist of comparably valued U.S. and Chinese products for import. The valuation of these products was determined based on annual bilateral trade values from the calendar year 2024.
Future tariff reductions for the approved products will follow each country's domestic legal processes. Both the US and China will monitor and assess trade involving these products and may propose adjustments for consideration, although such adjustments are not anticipated more frequently than annually.
There is room for potential expansion of the framework to include additional products. Discussions regarding this expansion may lead to proposals if deemed appropriate.
Following the announcement, U.S. Trade Representative Jamieson Greer emphasized that any tariff reductions affecting the identified 77 U.S. import categories are subject to a public comment process under Section 301 before implementation. Thus, any tariff relief is contingent upon further governmental action and is not automatic.
The US Import List includes a diverse range of products primarily categorized into household items, textiles, kitchenware, personal care appliances, children's furniture, toys, sporting goods, and festive decorations. Key items include fireworks, plastic tableware, electric blankets, various types of linen, wall hangings, domestic electromechanical appliances, Christmas ornaments, billiard equipment, children's highchairs and play yards, pillows, toys, sporting balls, fishing equipment, brushes for cosmetics, and vacuum flasks.
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Technical Corrections to Section 232 Duties on Pharmaceutical Imports
CBP has issued CSMS #70054007, announcing five technical corrections to the Section 232 tariff framework governing pharmaceutical imports. These amendments clarify definitions, introduce a new HTSUS subheading, refine scope language, and align Annex I with the July 1, 2026, HTSUS revisions. Importers of pharmaceutical and animal health products should review these changes to ensure correct classification and duty assessment.
Correction 1 — Revised Definition of "Generic Pharmaceutical Articles" (9903.04.67)
The definition of "generic pharmaceutical articles" under HTSUS heading 9903.04.67 has been expanded to include unpatented animal health products. This correction ensures that veterinary generics—previously ambiguous in their classification—are explicitly captured within the heading's scope, providing greater certainty for importers of animal health commodities.
Correction 2 — Introduction of New Heading HTSUS 9903.94.70 (Zero Ad Valorem Rate)
A new Chapter 99 special provision, HTSUS 9903.94.70, has been created and assigned a zero percent (0%) ad valorem tariff rate. This heading provides a dedicated classification pathway for goods that qualify under its terms without incurring additional Section 232 duty liability. Importers should review the full heading text to determine eligibility.
Correction 3 — Refined Definition of "Pharmaceutical Articles"
The term "pharmaceutical articles" has been clarified to encompass only: (a) finished pharmaceutical products ready for end use; (b) active pharmaceutical ingredients (APIs) used in those finished products; and (c) key starting materials (KSMs) critical to API synthesis. This narrowing of scope removes ambiguity around intermediate chemical compounds and bulk substances that do not qualify as APIs or KSMs.
Correction 4 — Updated Subdivision (i) Text for Heading 9903.04.69
The text of subdivision (i) under HTSUS heading 9903.04.69 has been revised to more precisely delineate the goods covered. The amended language clarifies the classification boundaries applicable to this subheading and resolves prior interpretive inconsistencies regarding its interaction with other Chapter 99 provisions.
Correction 5 — Annex I Revised to Reflect July 1, 2026, HTSUS Changes; Annex IV
Eliminates Five Codes
Annex I has been updated to incorporate changes to the HTS, effective July 1, 2026. Concurrently, Annex IV has been amended to remove the following five HTSUS codes, which are no longer valid or applicable under the revised schedule:
• 2937.23.50
• 3002.13.00
• 3002.14.00
• 3002.15.00
• 3004.49.00
Entries previously filed under any of these eliminated codes should be reviewed for reclassification under the appropriate current HTSUS provision.
Recommended Action Item for Importers:
- Review product portfolios to determine whether any goods previously classified under the five eliminated Annex IV HTSUS codes (2937.23.50, 3002.13.00, 3002.14.00, 3002.15.00, 3004.49.00) require reclassification.
- Assess whether unpatented animal health products qualify as "generic pharmaceutical articles" under the revised definition for heading 9903.04.67.
- Evaluate applicability of new heading 9903.94.70 (zero ad valorem) to current or planned imports.
- Confirm that all imported pharmaceutical articles meet the refined definition — finished products, APIs, or key starting materials — to determine Section 232 duty applicability.
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CBP Issues Withhold Release Orders on Indonesian Palm Oil Due to Forced Labor Concerns
CBP has taken decisive action against palm oil imports from two Indonesian plantations, Mitra Aneka Rezeki (MAR) and Hardaya Inti Plantation (HIP), by issuing Withhold Release Orders (WROs) on their products. Effective immediately, CBP officers at all U.S. ports of entry will detain shipments of palm oil and derivative products from these companies. This move follows evidence suggesting the use of forced labor in their production processes.
The issuance of these WROs is based on violations of 19 U.S.C. § 1307, which prohibits the entry of goods made with forced labor into the United States. CBP's review found credible evidence, including interview transcripts, payroll records, harvest quotas, photographs, NGO and government reports, media articles, and academic research, indicating that MAR and HIP employ forced labor.
Key findings revealed that workers at these plantations face several indicators of forced labor, as defined by the International Labour Organization (ILO). These include debt bondage, wage withholding, deception, excessive overtime, poor working and living conditions, intimidation, and vulnerability abuse. Additionally, MAR workers experience retention of identity documents and isolation.
Importers affected by these orders have options to destroy, export, or prove their goods were not produced with forced labor.
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Import Restrictions on Canadian Products Announced by U.S. Customs and Border Protection
CBP has issued CSMS #70050970, detailing new restrictions on the importation of specific Canadian products into the United States, effective from September 29, 2026, at 12:01 a.m. Eastern Time. These products are excluded from entering U.S. Foreign Trade Zones or bonded warehouses, in-bond transportation, and direct entry for consumption. Any shipments containing these products will be rejected by CBP starting at the specified time.
The annexes provided with the guidance list the HTSUS classifications affected, including certain commodities under headings 0404, 1702, 1703, 2202 to 2208, and 8711. For alcoholic beverages, the exclusion applies only to those packaged for direct consumption, while others remain subject to the 50% duty.
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