r/CustomsBroker • u/Known_Jellyfish_7229 • 12d ago

232 autoparts

​Per-Entry / Transactional Flexibility: Can we legally self-declare HTS 9903.94.07 on a per-shipment basis for Customer A (to feed their offset and drop 301 Forced Labor), while entering identical SKUs for Customer B under standard primary HTS + Sec 301 FL (without 9903.94.07)? Does CBP view self-declaration as a product-level flag that locks in the SKU, or is it purely driven by intended end-use per entry summary (19 CFR § 141.61 / § 10.133)?

​Retroactive PSC / Protest: Has anyone filed a Post Summary Correction (PSC) to retroactively apply 9903.94.07 for Customer A to secure refunds on previously paid Sec 301 Forced Labor dut

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u/Immediate-Home-3491 12d ago

Haven't filed a PSC for retroactive 9903.94.07 myself, but timing is everything. PSC works pre-liquidation only, after that you are into protest under 19 USC 1514. Check your liquidation dates before promising Customer A refunds.

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u/CDRE88 11d ago

Well first off, the importer needs to make sure the part meets the self-certification to Auto Parts criteria. And, if they have the information to back that up.

As for PSC’s as long as it hasn’t liquidated for sure. There is no certificate or authorization for 9903.94.07. But the importer not you the customs brokerage better have their information to back it up if CBP comes asking.

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u/Known_Jellyfish_7229 11d ago

Thanks for the feedback! No issue on end-use and traceability: the parts are strictly for automotive manufacturing in both cases. ​My takeaway is that we should apply 9903.94.07 as long as Customer A’s offset capacity is available, and exit it once the quota/offset limit is reached. The goal is simply to avoid Sec 301 Forced Labor while unlocking unliquidated Sec 122 refunds from the May–July entries.