Section 301 Differential Tariffs and Section 232 Product Tariffs Likely to Remain
KITA: "Korean Exporters Must Revise U.S. Export and Supply Chain Strategies"

As the United States moves forward with tariff refunds under the International Emergency Economic Powers Act (IEEPA), there are growing expectations that the high-tariff stance under Section 301 of the Trade Act and Section 232 of the Trade Expansion Act will remain in place. In particular, with the U.S. government signaling additional tariff measures targeting overproduction by countries such as China, experts point out that Korean export companies must review refund procedures while also overhauling their supply chain management and U.S. export strategies.


The Korea International Trade Association (KITA) held a "U.S. Tariff Measure Changes and Tariff Refunds Seminar" at COEX in Samseong-dong, Gangnam-gu, Seoul, on July 29.


This seminar was organized to share updates on U.S. tariff measures categorized by type—including those related to forced labor under Section 301 announced by the United States Trade Representative (USTR) on July 23 (local time)—the current status of local tariff refunds, and practical considerations. The event consisted of three sessions: ▲ Tariff measures under Section 301 and response strategies; ▲ IEEPA tariff refunds and trends in lawsuits related to Section 122 tariffs; and ▲ Section 232 tariff restructuring and key issues. More than 150 representatives from exporting companies attended.


Korea International Trade Association building. KITA.

Korea International Trade Association building. KITA.

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Cho Seongdae, Director of Trade Policy Research at KITA, forecast that the high-tariff stance based on Section 301 would persist even after the expiration of Section 122 tariffs. He stated, "Despite debates over the legal legitimacy of these measures, the United States will continue to maintain country-specific tariffs through Section 301 of the Trade Act and product-specific tariffs under Section 232 of the Trade Expansion Act." He added, "Companies should take a comprehensive approach, considering upcoming production-overcapacity actions under Section 301, as they establish their management and export strategies."


Taejoo Kim, Executive Director at Samjung KPMG, explained the current status of tariff refunds under IEEPA and the litigation trends regarding Section 122 tariffs. Kim noted, "With the U.S. Customs and Border Protection (CBP) launching its refund processing system in April, uncertainties have been resolved and actual refunds are now being processed." He emphasized, "As procedural details can differ for each company, it is important for businesses to actively utilize refund opportunities with the help of customs experts."



Jongseon Shim, Partner at Deloitte Anjin, shared recent developments in the enforcement of product tariffs under Section 232 of the Trade Expansion Act and related practical considerations. Shim discussed the restructuring of steel, aluminum, and copper tariffs from value-based to gross amount-based assessments, and advised, "Since the U.S. CBP is stepping up import restrictions related to forced labor and intensifying its crackdown on trade fraud in order to enhance the effectiveness of these measures, meticulous supply chain management is essential."


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