GSP Products and Country Review Open for Comments

Comments Open

The Office of the U.S. Trade Representative will collect comments until April 18 @ midnight EST for its annual Generalized System of Preferences (GSP) product and country review.

The agency states it will consider petitions for the following reasons:

  • to modify the GSP status of GSP beneficiary developing countries (BDCs) because of country practices;
  • add products to GSP eligibility;
  • remove products from GSP eligibility for one or more countries;
  • waive competitive need limitations (CNLs);
  • deny de minimis waivers for products eligible for de minimis waivers;
  • and redesignate currently excluded products.

The agency states, “This review will include separate hearings on product petitions and country eligibility reviews, which USTR will announce in the Federal Register at a later date.”

What is GSP?

The Generalized System of Preferences (GSP) program provides for the duty-free treatment of designated articles when imported from designated beneficiary developing countries.  In fact, the USTR just recently announced it will terminate GSP designation of India and Turkey, which are expect to take effect in May 2019.


Moreover, the Trump Administration is taking a more active approach to enforecement of the GSP, which according to Sandler, Travis and Rosenberg, is a “shift [that] presents both challenges and opportunities for companies utilizing this program.”

The international trade law firm goes on to state the eligibility requirements for GSP,

GSP“Since 1974 GSP has eliminated tariffs on about 3,500 products when imported from any of 120 beneficiary developing countries and territories. GSP also provides benefits for about 1,500 additional products from least-developed countries. The program has most recently been authorized through Dec. 31, 2020.

To benefit from GSP a product must be either wholly obtained or sufficiently manufactured in a BDC. Sufficiently manufactured means that all third-country materials have undergone a substantial transformation and at least 35 percent of the good’s value has been added in the BDC. The product must also be imported directly from the BDC.

In addition, BDCs must meet statutorily-established eligibility criteria, including respecting arbitral awards in favor of U.S. citizens or corporations, combating child labor, respecting internationally recognized worker rights, providing adequate and effective intellectual property rights protection, and providing the U.S. with equitable and reasonable market access.”

GSP Training

GSP Comments until April 18

The GSP program, along with other duty savings and recovery options can be complex.  That’s why Scarbrough is offering a free online question and answer session on June 19, 2019.  This session will be recorded, so register even if you can’t make it.  We will talk about GSP, duty drawback, product exclusions, FTZs, FTAs, and more.

[maxbutton id=”31″ url=”” text=”Register Now” ]

 If you are in Kansas City, Saint Louis, Des Moines or Omaha, we encourage you to come to our seminar in person.  Kansas City and Saint Louis will be this spring and Des Moines and Omaha will be in the fall.  Find out more.

USTR Report

The USTR also released the 2019 GSP Annual Product Review Report: 2018 Statistics Relating to Competitive Need Limitations (CNLs), De Minimis Waivers and Product Redesignations.  Click here for the report.

Submit a Formal Comment:

USTR strongly prefers electronic submissions made through the Federal eRulemaking Portal: Follow the instructions for submitting comments in Section III of this Federal Register Report.

The docket number is USTR-2019-0001.

For alternatives to on-line submissions, please contact Lauren Gamache at, or 202-395-2974.

We can help!  Please email to talk to someone.