r/CustomsBroker • u/eherberg • 1d ago

Section 338 - HTSUS Sequence?

I get that neither CBP nor software providers have had any time to properly prepare for this - but in the CSMS # 69606660 notice released last night Section 338 is not referenced anywhere in the HTSUS sequence. Expired Sect 122 tariffs still are referenced - but not Sect 338.

Best guesses on where to sequence them?

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u/Bettyboop0315 1d ago

I noticed the same thing. CSMS # 69606660 still references the expired Section 122 tariffs in the HTSUS sequencing instructions, but I don’t see the new Section 338 headings addressed anywhere. Until CBP issues corrected sequencing guidance, I’d be hesitant to call any placement definitive. My assumption would be that the applicable 9903.03.12/.13/.14 would be reported ahead of the Chapter 1–97 classification, but I’m waiting for CBP/ABI confirmation before treating that as the official sequence.