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Trade Commission Re-Opening Comment Period on Certain MTB Petitions

Posted May 06, 2020


The U.S. International Trade Commission has advised that it plans to offer a limited opportunity to submit additional comments on some petitions for duty suspensions and reductions; specifically, those it would presently not otherwise recommend for inclusion in the next Miscellaneous Tariff Bill.

USITC Seal, Congress, Money-Saving

The MTB Petition System


MTB petitions are legislative vehicles used to provide temporary duty relief on certain qualified products (usually intermediate goods, such as chemicals, electronic components, and mechanical parts that are not domestically available) typically used as inputs in U.S. manufacturing operations.

Under changes made in recent years by the American Manufacturing Competitiveness Act, importers must now file a petition directly with the USITC. The Commission requests public comment on the petitions received and then issues preliminary and final reports recommending those which should be included in an MTB for Congressional consideration.

2020 Miscellaneous Trade Bill


The Commission is expected to send its preliminary report to Congress on June 9. In it, the submitted petitions requesting duty elimination/reduction will be categorized as follows:

  • Category I – Meets the statutory requirements for inclusion in an MTB without modification.
  • Category II, III, or IV – Meets the statutory requirements with specified technical changes, changes in product scope, or adjustments in the amount of duty reduction.
  • Category V – Does not contain the required information or was not filed by a likely beneficiary.
  • Category VI – Not recommended for inclusion in an MTB.

Additional Comment Period


The Commission has decided to re-open the Miscellaneous Tariff Bill Petition System (MTBPS) comment portal for an additional ten days — June 12 through June 22, 2020 — to allow for supplementary information to be provided regarding petitions in Category VI in the preliminary report.

Comments may address various issues affecting the placement of a petition in category VI, but the Commission is essentially looking for information that either helps to verify the proper tariff classification of the goods covered in a petition (so-called “administrability”), or that could distinguish the product in question from others in such a way as to possibly mitigate objections from domestic manufacturers.

Note: The ITC will not consider comments that seek to broaden or materially amend the nature of the goods as originally described in the petition.

Need More Information?


Click here for additional resources and information about the Miscellaneous Trade Bill. A timeline of the current MTB process can also be found here. If you have questions about this or other duty relief mechanisms, don’t hesitate to contact one of our trade experts today.

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