Updated (Aug 14, 2020):
We just received the following confirmation on Goods made in Hong Kong and Section 301 Duties:
Whereas the goods must be marked "Made in China" CBP’s guidance states that this marking change “does not affect the country of origin determinations for purposes of assessing ordinary duties under Chapters 1-97 of the HTSUS or temporary or additional duties under Chapter 99 of the HTSUS,” which include the Section 301 tariffs on imports from China. As a result, CBP states, “goods that are products of Hong Kong should continue to report … country code ‘HK’ as the country of origin when required.”
In summary, if your goods originate from Hong Kong:
Labeling: Must be labeled as originating in China.
Customs Invoice: Must list Hong Kong as the Country of Origin
Duties: 301 Section duties levied against goods originated in China will not be applied to these goods originating in Hong Kong.
President Trump has issued an Executive Order suspending special trade status to Hong Kong effective November 9, 2020.
July 14, 2020, Executive Order 13936, was issued declaring that Hong Kong was no longer sufficiently autonomous to justify differential treatment in relation to China.
This came about as a result of a declaration made by China in May 2020, that it was their intention to unilaterally impose national security legislation on Hong Kong.
This announcement was just one of the latest moves by China to deny the autonomy and freedoms that China promised to the people of Hong Kong under the 1984 Joint Declaration of the Government of the United Kingdom of Great Britain and Northern Ireland and the government of China on the question of Hong Kong.
How Will This Affect My Imports From Hong Kong?
Goods manufactured in Hong Kong will now have to be marked “made in” or “product of” China.
Will My Goods Be Subject To Section 301 Duties Levied Against Goods Made In China?
As far as we know right now, the answer is no. International Trade today reported that a senior administration official indicated that Chinese tariffs would not be levied on goods from Hong Kong. The policy may be adjusted as conditions warrant.
We will keep you updated on this story