Richard Mojica Comments on Steps to Navigate MTB System in Law360

"5 Tips For Navigating The New MTB Process"

Richard Mojica commented on what companies can do to achieve cost savings under the temporary duty-suspension legislation known as the miscellaneous tariff bill (MTB). The process for applying to receive a tariff cut under the MTB has been overhauled, but much of the legwork that companies must do remains unchanged. In addition to demonstrating that there is no domestic production for the product in question, “companies must show that the U.S. government's estimated revenue loss for that product will not exceed $500,000 in a calendar year, which requires a careful analysis of import figures, Mojica said. "What you want to identify are high-volume products for which you are paying significant duties on a yearly basis. Generally, companies know what those products are, but by sorting the data you can more easily identify those high-volume, high-duty products," he added.

Mojica encourages companies to be specific in the information included in an MTB petition to the International Trade Commission (ITC), and said that in addition to providing the eight- or 10-digit classification under the U.S. Harmonized Tariff Schedule, importers should include technical specifications of a product whenever possible. "You have to think creatively about how you are going to describe the product to the ITC," he said. "A product should be described as narrowly as possible so as to get a competitive advantage over other importers of similar products."

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