New Import Tariffs for Aircraft Parts from Belarus or Russia

Very little is being imported from Russia these days, but if you are importing Russian aviation products then you need to be aware of the unusual tariff treatment of those goods.

There is a “column two” in the harmonized tariff system of the United States. Column two is used for nations with whom the United States does not have normal trade relations (currently Cuba, North Korea, Russia and Belarus). Column two imposes much higher import duties. In April, Congress (P.L. 117-110 § 3(a) (April 8, 2022)) determined that column two would apply to products of Belarus and Russia. This means that aircraft parts from these two jurisdictions lose their duty-free status.

In today’s Federal Register, the President proclaimed a change in the column two duties that apply to many products from Russia, including certain aviation products and parts. This does not (yet) apply to Belarus. In essence for any affected goods, the 35% duty replaces whatever duty was normally established in column two.

For example, imagine you are importing a unit load device that is a product of Russia. It falls under tariff code 8609.00.00.00, which is for containers. As a container, it would have been subject to free (zero duty) entry under column one, but it would have been subject to a 25% duty under column two.

But under the new tariff rules, the same container will be subject to a 35% duty if it is imported from Russia.

Many aircraft parts under heading 8807 will be affected by this new rule (including those under 8807.10.00, 8807.20.00, 8807.30.00 and 8807.90.90. These new tariff rules apply only to Russia (not Belarus) and they go into effect on July 27, 2022.

For a complete list of the affected products, as well as full details on this new provisions, review the Presidential Proclamation in the Federal Register.