On August 12, CBP confirmed that the recent revocation of Hong Kong’s “special status” and updated China marking requirements would not render goods of Hong Kong origin subject to the additional Section 301 tariffs imposed on most goods of Chinese origin. CBP stated that “the change in marking requirements does not affect country of origin determinations for purposes of assessing ordinary duties under Chapters 1-97 of the HTSUS or temporary additional duties under Chapter 99 of theHTSUS. Therefore, goods that are products of Hong Kong should continue to report International Organization for Standardization (ISO) country code ‘HK’ as the country of origin when required.”

However, imported goods that are produced in Hong Kong that are entered, or withdrawn from warehouse, for consumption into the United States after September 25 must be marked to indicate that their origin is “China” for purposes of 19 U.S.C. § 1304.

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