INSIGHTS
Few pages, maintained monthly, every figure cited to its authority. Nothing here is commentary.
THE ANCHOR · UPDATED MONTHLY
Every duty layer on HTS 8504.40.85, 8504.40.95, and 8544.42.90 for China, Vietnam, and Mexico — each cited to the HTSUS, the Federal Register, or the executive order that created it.
Verified · changelog on page · read →
QUESTION ·
Yes — if the charger is substantially transformed in Vietnam. Section 301 duties (25% on List 4A, per 84 FR 43304) apply to goods of Chinese origin, and origin is set by where transformation occurs, not where the box is sealed.
For switching power supplies, CBP looks at transformer winding, PCB assembly, and programming. If those happen in Vietnam, the charger is Vietnamese even with some Chinese components inside. If Vietnam only does final assembly and packaging of Chinese subassemblies, it is still Chinese — and entering it as Vietnamese is transshipment, penalized at 40%.
The §122 surcharge (10% as of ) applies regardless of origin. Vietnam origin removes the §301 layer only: 35.0% becomes 10.0%.
QUESTION ·
Demand the entry documents, not the marketing. Four papers settle it: the CBP Form 7501 from a prior entry, a per-shipment certificate of origin, mill certificates for magnetics and enclosures, and the supplier's written substantial-transformation analysis.
Ask for them before you re-source. The speed and completeness of the answer tells you most of what you need to know.
For certainty, request a CBP binding ruling under 19 CFR Part 177: it names your SKU and binds CBP at every port. Kestner files these for customers' SKUs on request.
QUESTION ·
The statute caps it at 150 days without Congressional action — but plan pricing as if it stays. Section 122 of the Trade Act of 1974 (19 U.S.C. §2132) authorizes a surcharge of up to 15% for balance-of-payments purposes, limited to 150 days unless extended by Congress.
The current 10% surcharge took effect . If it lapses, China's effective rate on these HTS codes falls to 25.0% and Vietnam's to 0% — the 25-point delta between them is §301, and it does not expire with §122. We reprice DDP quotes the week any layer changes.
Rates verified [DATE] against HTSUS Rev. [N]. Not customs or legal advice.