‍SGC Guideline for Requesting Tariff Refunds on PCB Imports

‍Background: Some of our customers importing 2-layer PCBs (HTSUS 8534.00.0040) and 4-layer PCBs (HTSUS 8534.00.0020) into the U.S. have been charged a 25% tariff under Section 301. However, these products may qualify for the exclusion under HTSUS 9903.88.69. In such cases, these tariffs may be refundable if the products were misclassified, excluded, or qualify under updated CBP rulings.

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‍Step 1: Confirm Eligibility
Refunds may apply if:

• Your imports include 2-layer or 4-layer PCBs that were assessed the 25% duty under Section 301.
  
• You can provide proof of duty payment.
  
• Your shipment falls under a tariff code eligible for reclassification, exclusion, or refund based on CBP guidance.
  

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‍Step 2: Collect Required Documentation‍

• ‍PCB drawings
• Certificate of Conformance (CoC)
• Layer stack-up documentation
• Product brief or technical introduction for 2-layer and 4-layer PCBs
• Entry Summary (Form 7501), Commercial Invoice, and Packing List (these may be available from UPS, your express carrier, or customs broker if they handled the clearance)
  
• Supporting documentation (if applicable)

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‍Step 3: Contact Carrier or Customs Broker

• Contact Express Carrier (UPS, FedExor, DHL) or customs broker who filed your original import entry.
• Ask them to review entries where the 25% Section 301 tariff was charged.
• Provide all required documentations in step 2 to confirm product classification and eligibility for a refund.

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‍Step 4: Filing the Claim with CBP
All tariff refund claims are submitted electronically by your carrier or customs broker through the Automated Commercial Environment (ACE) Portal, depending on the status of your shipment. It is important that you follow up directly with your carrier or broker to ensure the correct filing method is used and that the claim has been submitted successfully within the required timeframe.
- There are two primary filing methods:

• Post Summary Correction (PSC): Used for shipments filed within the past 300 days that have not yet been liquidated.
• Protest: Used for entries that have already been liquidated, and the request is made within 180 days of liquidation.

‍Step 5: CBP Review and Processing

• CBP reviews the submitted claim to verify the products eligibility for a refund.
• The review process may take several weeks to several months, depending on the claim volume and complexity.
• Track the status of your claim through the ACE Portal or through your carrier.
• During the stage, CBP may request additional documents from your carrier or broker. Ensure they respond promptly to avoid delays.

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‍Step 6: Refund Issuance

• Once approved, CBP issues the refund directly to the importer of record (the entity listed on the entry).
• Refunds are credited electronically through your carrier, broker, or the ACE system. Processing may take several weeks to months.

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‍Step 7: Recordkeeping and Follow-Up

• Retain all related documents, refund confirmation, and reference number to the claim for at least five years from the date of filing.
• Track all refund claims, correspondence, and CBP responses.
• For future shipments, coordinate with your carrier/broker to ensure the correct HTSUS code and Section 301 exclusions are applied.

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‍How We Can Help
‍At Sunshine Global Circuits, we are committed to supporting our customer throughout the tariff refund process by:

• Providing product specifications and technical documentation to confirm eligibility.
• Assisting with documentation requests from your carrier.
• Offering guidance on the process of tariff refunds for printed circuit boards.