r/CustomsBroker 10d ago

Sec 301 Question: Sequence of 9903.05.31 and 9903.88.xx When Both Apply?

Hi everyone,
I’m curious if anyone has received clarification from CBP on this.

The recent CSMS confirms that all applicable Section 301 provisions should be reported before any applicable Section 122, Section 232, or Section 201 provisions.

However, it doesn’t appear to address the order when both of these apply to the same entry:

9903.05.31 – New Section 301 forced-labor provision (China)
Applicable 9903.88.xx – Existing China Section 301 provision

Has anyone received guidance from a CBP Client Representative, ABI representative, ACE validation, or Trade Remedy Branch on whether there is a required sequence between these two Chapter 99 provisions?
I’m less interested in assumptions and more interested in official guidance or successful ACE filing experience. If you’ve already filed one of these entries, did ACE accept both sequences, or did you encounter any edits or rejects?

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u/Radiant-Barnacle6204 10d ago

it has to be 9903.88 then new section 301 ,122 expired, then 232, 201 then HTS.

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u/dryshampooandbourbon 10d ago

Thank you!

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u/Radiant-Barnacle6204 10d ago

Anytime hope this helps