Holy hell my head is spinning (re: tariffs and pcb fab/assembly)

[Spike]

Hey all.  I had intended to start yet another thread discussing alternatives and options for PCB fabrication and assembly, but this time purely from a hobbyist perspective as I know there are already a couple of threads that seem more geared to small business needs.

With things changing nearly daily, though, it seems a good thing I waited a day.  The latest news as I write this is that yet another exemption has been carved out for smartphones, computers and "other electronics."  I was already struggling to understand what was included in the tariffs and how much exactly they are, and now this.

I managed to find this CPB document from yesterday which enumerates the exemptions:

https://content.govdelivery.com/accounts/USDHSCBP/bulletins/3db9e55

and this database in which the category numbers from the above documents can be looked up:

https://hts.usitc.gov

My problem now is that the descriptions of those items still leaves me scratching my head.  I am neither an importer, exporter nor manuracturer, so I still cannot translate this to our concerns with regard to PDB fabrication and assembly.

I defer to the bright minds on this forum.  Does anyone here:

a.) Already know how the tariffs impact PCB orders from the usual vendors of PCB services such as JLCPCB, PCBWAY, etc., or
b.) can decipher information from the provided links to ascertain the impact or specifically tell whether these services would now be exempt?

As always, many thanks in advance.

[themadhippy]

surely your the importer as its you who has contracted the company to supply you  and you who is paying  for it

[forrestc]

You're actually legally the importer.

Regardless:

Blank PCB are 8534.00.00 which are not exempt.

Assembled PCB's are categorized by use and *may* be exempt.  I.E.  If you have an assembled PCB which is for data processing equipment which is described under 8471, then the boards are under 8473.30 which is exempt.   Other assembled PCBs may not be exempt depending on their end use.

Effectively you have to figure out what category they will clear into the US under and then figure out if that is exempt.

[Spike]

surely your the importer as its you who has contracted the company to supply you  and you who is paying  for it

Yes, understood, but that's not what I meant by my comment.  What I  mean is that it is not my profession and therefore I do not understand the intricacies of how to import or export, nor do I understand the laws and regulations.  That is why I'm posting here because I suspect that there are many people who deal with this sort of thing frequently and can better decipher the information presented.

[Spike]

Effectively you have to figure out what category they will clear into the US under and then figure out if that is exempt.

and who makes this determination?  The exporter in China?  The CPB official?  I literally have no idea.  It seems to me that the exporter could call it whatever they want.  Who's to say otherwise?

[tggzzz]

You're actually legally the importer.

Regardless:

Blank PCB are 8534.00.00 which are not exempt.

Assembled PCB's are categorized by use and *may* be exempt.  I.E.  If you have an assembled PCB which is for data processing equipment which is described under 8471, then the boards are under 8473.30 which is exempt.   Other assembled PCBs may not be exempt depending on their end use.

Effectively you have to figure out what category they will clear into the US under and then figure out if that is exempt.

And next week will the answer be the same?

Who is responsible for remitting the monies to the government?

[aeg]

Effectively you have to figure out what category they will clear into the US under and then figure out if that is exempt.

and who makes this determination?  The exporter in China?  The CPB official?  I literally have no idea.  It seems to me that the exporter could call it whatever they want.  Who's to say otherwise?

The exporter declares it on the commercial invoice. CBP can decide they disagree. Some shipments receive more scrutiny than others.

[Spike]

Blank PCB are 8534.00.00 which are not exempt.

So this is interesting, and where it starts to get complicated for me.  As I said I don't really understand this stuff very well.  If I search the database for this classification number I see this:



The information icon up top reveals this:



Hovering over "Free 1/" says to refer to 9903.88.03, which then begins a thread of classification numbers which add special tariffs to the "Free" tariffs in 8534.00.00.  It was really hard to follow that thread so I've paused for now.  Basically, though, it sounds like for bare PCBs it may just be easier to pay more to a U.S. board house, unless you know for certain you won't get an unfortunate surprise from CPB.  This ignores the lovely fees that the carrier gets to charge you for the privilege of collecting the tariffs from you.

[forrestc]

And next week will the answer be the same?

The category number should almost always never change for a specific item, once it has been properly determined.  The main exceptions are where a category is split or combined based on needing finer or coarser categories.  I.E. if you were importing wheat, you might find that wheat gets split into wheat, GMO and wheat, non-GMO.   And, I suspect the number for things like GNSS receivers just didn't exist a hundred years ago.

As to the tariff rate changing, ask the guy in the white house or the people in congress.

I do need to clarify that I'm not sure exempt was the correct word in my previous post. I meant exempt from the additional tariffs as described in the document.  This whole thing is weird in that they'll say "45%" but they really mean "45% more than what we were charging a year ago".   So, I don't know for sure the rate previously.

Who is responsible for remitting the monies to the government?

Under typical terms of sale, The importer is responsible to pay the duty.   Usually the remittance to customs is done by whoever is acting as customs broker - often the shipping carrier.  But the importer ends up paying them even if they end up paying the broker and the broker pays the government.

Sometimes you'll find a seller who includes the duties in the cost.  In this case it is the seller, and then they pay the duty.

(I've purposely simplified this last part as understanding INCOTERMS is another confusing part of international trade).

[tggzzz]

Yes, I was thinking of the tariff rate rather than the magic classification number.

My strictly UK personal experience is that the shipper remit the monies, but I pay the money plus an irritatingly high admin fee to the shipper.

[forrestc]

So this is interesting, and where it starts to get complicated for me.  As I said I don't really understand this stuff very well.

Join the crowd. 

I've trimmed the images, so if anyone wants to follow along - look at the previous post.

Column 1 is for countries with normal trade relationships.

Column 2 is for countries without normal trade relationships.  Belarus, Cuba, North Korea, and Russia are the ones which I'm aware of - there might be others. 

So, China and everywhere else you're likely to buy from is a column one country.   Which is normally free - with the exception of the exceptions referred to in /1

Hovering over "Free 1/" says to refer to 9903.88.03, which then begins a thread of classification numbers which add special tariffs to the "Free" tariffs in 8534.00.00.  It was really hard to follow that thread so I've paused for now.  Basically, though, it sounds like for bare PCBs it may just be easier to pay more to a U.S. board house, unless you know for certain you won't get an unfortunate surprise from CPB.  This ignores the lovely fees that the carrier gets to charge you for the privilege of collecting the tariffs from you.

So 1 refers to you 9903.88.03 which says "anything from china gets 25% tacked on the rate listed in column 1, with pointers to a whole bunch of other exceptions to the exceptions which may end up with higher or lower rates".  However, a quick glance doesn't show any exceptions that end up at a higher than 25% rate as far as column 1 goes. 

HOWEVER.... A lot of those sections also refer you to the chapter notes, and that's where these additional tarrifs are being added, apparently.  And if you think 9903.88.03 is hard to figure out, well, start reading those notes, especially since some of the notes suspend other notes, and on and on.   So yes, it's hard to know.

Here's my position on buying PCB's from China right now:

I expect to pay whatever the US "maximum" duty that the US president keeps spouting on PCB's.   Maybe 145% right now IIRC?  Haven't checked today yet. , and then I'm happy if I get it at a lower rate.

When you compare the pricing on China-origin PCBs with US-origin PCBs, you find that the tariffs would need to be something like 1000% or more for the US-origin ones to be cheaper.  So while it makes sense to compare, I also realize that close to tripling the prices isn't going to change where is least expensive.

Now, if you could find a board house in Taiwan or somewhere like that ....

[forrestc]

Yes, I was thinking of the tariff rate rather than the magic classification number.

My strictly UK personal experience is that the shipper remit the monies, but I pay the money plus an irritatingly high admin fee to the shipper.

Yeah, part of the international shipping game is getting the fees down.

Typically if I have an open account with automated payment instructions with the shipping company (UPS, DHL, etc.) they still charge me a "customs paperwork fee" but don't charge the egregious "remittance fee" which I believe is better named the "we want to pay this so these things don't clutter up our warehouse and we can deliver it to you, but if we do so we know some of you won't pay the customs duty, so we're just going to charge a large enough remittance fee so that we get enough from those who do pay to cover the losses from those who don't" fee.

As a manufacturer, this whole "never know what the duty amount is going to be" thing is causing planning/purchasing nightmares.  I have roughly $5K USD of cables+connectors on a ship from china to here - and it was shipped before all these duties started happening.  I was worried that it was going to be a $12,500 box by the time it got here - until I found out that they exempted packages in transit.   But... most things I buy from China take 30 days from PO to shipping and who knows what the rate will be 30 days from now.

[sleemanj]

I expect to pay whatever the US "maximum" duty that the US president keeps spouting on PCB's.   Maybe 145% right now IIRC?  Haven't checked today yet. , and then I'm happy if I get it at a lower rate.

The simple answer is nobody really knows. 

Under the assumption we are talking about imports valued under $800 here, it appears it will depend on the carrier who brings it across the border as to how it's going to be charged.

The last I understood was that the carrier appears to have a choice between applying the actual tariff % or using the flat rate of $75 (increasing to $150 in June) US$100, increasing to US$200 from June 1 (edit: changed again), but once they choose they must use the same for all parcels for a month, they can change their choice once a month.

I think it is safest to assume that your import arriving at the border on or after May the 2nd will be slapped with the greater of

  * The tariff plus handling fees from the carrier
  * The flat rate of $75 ($150 from June) $100 ($200 from June) plus handling fees from the carrier

as to how you will be asked to pay, again that's down to the carrier.

[Spike]

So this is interesting, and where it starts to get complicated for me.  As I said I don't really understand this stuff very well.

Here's my position on buying PCB's from China right now:

I expect to pay whatever the US "maximum" duty that the US president keeps spouting on PCB's.   Maybe 145% right now IIRC?  Haven't checked today yet. , and then I'm happy if I get it at a lower rate.

When you compare the pricing on China-origin PCBs with US-origin PCBs, you find that the tariffs would need to be something like 1000% or more for the US-origin ones to be cheaper.  So while it makes sense to compare, I also realize that close to tripling the prices isn't going to change where is least expensive.

Now, if you could find a board house in Taiwan or somewhere like that ....

and I guess here is where i land as well.  I have no qualms about spending my money in China or any other country where the products and services I need are efficiently priced and the overall friction of the transaction is reasonable.  It's that last part, modulo the tariffs, where I feel the Chinese vendors have excelled over recent years.  They've optimized their business to make the friction low for hobbyists.

The part where it becomes problematic is the administration of tariffs.  The uncertainty is off the charts right now and subject to, uh, whims. It's really hard to know from day to day what I'm going to pay, and not knowing the final price until after my boards arrive is less than ideal.

Where U.S. based vendors have fallen down in my opinion is that no effort has been made to go after the market space filled by these Chinese vendors and hence the friction is high and the pricing is not great.  Board aggregator OSH Park has stagnated where they were when they started, IMO, and the breadth of their offerings pale in comparison (ignoring assembly altogether).

I've tried to look at actual manufacturers like Sierra Circuits, RushPCB and PCB Unlimited but their ordering processes similarly seem to have high friction as well as having prices that make the proposition not that appealing.

[Smokey]

...
I managed to find this CPB document from yesterday which enumerates the exemptions:
https://content.govdelivery.com/accounts/USDHSCBP/bulletins/3db9e55
and this database in which the category numbers from the above documents can be looked up:
https://hts.usitc.gov
...

HTS Code   Product Description
8471   Automatic data processing machines and units thereof; magnetic or optical readers, machines for transcribing data onto data media in coded form, and machines for processing such data.
8473.30   Parts and accessories of the machines of heading 8471, specifically parts and accessories of automatic data processing machines.
8486   Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits, or flat panel displays.
8517.13.00   Smartphones.
8517.62.00   Machines for the reception, conversion, and transmission or regeneration of voice, images, or other data, including switching and routing apparatus.
8523.51.00   Solid-state non-volatile storage devices for the recording of sound or other phenomena.
8524   Records, tapes, and other recorded media for sound or other similarly recorded phenomena.
8528.52.00   Monitors and projectors, not incorporating television reception apparatus, capable of directly connecting to and designed for use with an automatic data processing machine.
8541.10.00   Diodes, other than light-emitting diodes.
8541.21.00   Transistors, with a dissipation rate of less than 1 W.
8541.29.00   Other transistors, not specified elsewhere.
8541.30.00   Thyristors, diacs, and triacs.
8541.49.10   Other photosensitive semiconductor devices, including photovoltaic cells, assembled in modules or made up into panels.
8541.49.70   Other photosensitive semiconductor devices, including photovoltaic cells, not assembled in modules or made up into panels.
8541.49.80   Other photosensitive semiconductor devices, not specified elsewhere.
8541.49.95   Other photosensitive semiconductor devices, not elsewhere specified or included.
8541.51.00   Gallium arsenide light-emitting diodes (LEDs).
8541.59.00   Other light-emitting diodes (LEDs).
8541.90.00   Parts of diodes, transistors, and similar semiconductor devices; photosensitive semiconductor devices, including photovoltaic cells; light-emitting diodes; mounted piezoelectric crystals.
8542   Electronic integrated circuits and microassemblies.

[phil from seattle]

Where U.S. based vendors have fallen down in my opinion is that no effort has been made to go after the market space filled by these Chinese vendors and hence the friction is high and the pricing is not great.  Board aggregator OSH Park has stagnated where they were when they started, IMO, and the breadth of their offerings pale in comparison (ignoring assembly altogether).

I'm not at all surprised.  Why should they invest in building a business when tomorrow or next week or next year the capricious orange one will change his mind and wipe out any advantage they might have?  It's the uncertainty that kills business planning. When the future is completely opaque, go into defensive mode. Protect what you have and save capital for when the future is a lot less uncertain.

[Spike]

Where U.S. based vendors have fallen down in my opinion is that no effort has been made to go after the market space filled by these Chinese vendors and hence the friction is high and the pricing is not great.  Board aggregator OSH Park has stagnated where they were when they started, IMO, and the breadth of their offerings pale in comparison (ignoring assembly altogether).

I'm not at all surprised.  Why should they invest in building a business when tomorrow or next week or next year the capricious orange one will change his mind and wipe out any advantage they might have?  It's the uncertainty that kills business planning. When the future is completely opaque, go into defensive mode. Protect what you have and save capital for when the future is a lot less uncertain.

While I don't disagree with this sentiment in today's world, I really meant that they have never gone after this market, at least not aggressively.  They've had years to do it but have done virtually nothing.  OSH Park, who ostensibly entered the business for this very purpose, has had more than a decade to do something but is essentially where they started, with only a capability here or there different.

[phil from seattle]

Where U.S. based vendors have fallen down in my opinion is that no effort has been made to go after the market space filled by these Chinese vendors and hence the friction is high and the pricing is not great.  Board aggregator OSH Park has stagnated where they were when they started, IMO, and the breadth of their offerings pale in comparison (ignoring assembly altogether).

I'm not at all surprised.  Why should they invest in building a business when tomorrow or next week or next year the capricious orange one will change his mind and wipe out any advantage they might have?  It's the uncertainty that kills business planning. When the future is completely opaque, go into defensive mode. Protect what you have and save capital for when the future is a lot less uncertain.

While I don't disagree with this sentiment in today's world, I really meant that they have never gone after this market, at least not aggressively.  They've had years to do it but have done virtually nothing.  OSH Park, who ostensibly entered the business for this very purpose, has had more than a decade to do something but is essentially where they started, with only a capability here or there different.

Yes.  Although with essentially 0 tariff (ie de minimis exception), there was no way they could compete with the chinese fabs.  Even today, a 4x4 PCB from OSHPark is $80 (for 3) in 10 days while same board from, say, JLCPCB is around $50 (for 5) in about a week with 150% tariff ($20 incl shipping, no tariff).  Smaller boards from OSH are cheaper ($5 per sq in) so I typically only get boards from them that are < 4 in sq and can stand the wait.

By the way, the cheap/slow shipping option from JLC is a very good deal. Last time I did that, it took 12 days, cost $4.30 incl shipping so with 150% tariff it would cost  $10.75. Still not a lot of incentive for OSH.  I wish they could ship 10 Kg of PCBAs that way...

[mtwieg]

Honestly I would just log off for the week rather than try and keep up with this crap. It's clear that trying to figure out the rules is pointless because more changes are still incoming.

[NF6X]

I wish that I had a plausible reason to expect things to have stabilized in a week, but my feeling is that chaos and uncertainty will continue far longer than that. I can appreciate that some folks will choose to not order any PCBs from China while the chaos reigns, but what about folks who have reasons to not stop ordering boards?

I would appreciate it if US folks making small PCB orders from the China PCB manufacturers during this chaotic period could share their experiences. Did you see a sudden price increase from the vendor? Did the shipper hold your shipment for ransom, or did they deliver and then hit you with a tariff bill later? What has changed in your most recent China PCB fabrication experience vs. previous ones?

[Spike]

I wish that I had a plausible reason to expect things to have stabilized in a week, but my feeling is that chaos and uncertainty will continue far longer than that. I can appreciate that some folks will choose to not order any PCBs from China while the chaos reigns, but what about folks who have reasons to not stop ordering boards?

I would appreciate it if US folks making small PCB orders from the China PCB manufacturers during this chaotic period could share their experiences. Did you see a sudden price increase from the vendor? Did the shipper hold your shipment for ransom, or did they deliver and then hit you with a tariff bill later? What has changed in your most recent China PCB fabrication experience vs. previous ones?

While I’d love to just log off for a week rather than try to figure this out, my reasons for starting this topic were not just academic.  I just happened to be planning to order some boards when this crap started falling and I was genuinely trying to sort out my options.

I don’t expect this to stabilize in a week, or even a month or, under the current circumstances, even a year.  I would like to get some sense for how to navigate it, though.  I ended up deciding to just order bare boards from one of the Chinese board houses because neither OSH Park nor DK Red can fab the design I inherited and I don’t feel like laying it out again.  I’ll report back what I learn from this exercise.

[bson]

Under typical terms of sale, The importer is responsible to pay the duty.   Usually the remittance to customs is done by whoever is acting as customs broker - often the shipping carrier.  But the importer ends up paying them even if they end up paying the broker and the broker pays the government.

If you have a TIN the shipper will happily pass it on to you.  There is no hold at customs pending payment.  You can then pass it on to your customers as a tariff-specific invoice line item.  Not sure if you can do this as an individual, but I imagine probably if you have an account and/or submit the right paperwork (perhaps electronically or online) for the shipper to have on file.  Even though you wouldn't pass it on, you bypass the customs hold.

[NF6X]

Is the TIN that you refer to the same as the EIN issued to my LLC, or something else?

[phil from seattle]

I wish that I had a plausible reason to expect things to have stabilized in a week, but my feeling is that chaos and uncertainty will continue far longer than that. I can appreciate that some folks will choose to not order any PCBs from China while the chaos reigns, but what about folks who have reasons to not stop ordering boards?

I would appreciate it if US folks making small PCB orders from the China PCB manufacturers during this chaotic period could share their experiences. Did you see a sudden price increase from the vendor? Did the shipper hold your shipment for ransom, or did they deliver and then hit you with a tariff bill later? What has changed in your most recent China PCB fabrication experience vs. previous ones?

While I’d love to just log off for a week rather than try to figure this out, my reasons for starting this topic were not just academic.  I just happened to be planning to order some boards when this crap started falling and I was genuinely trying to sort out my options.

I don’t expect this to stabilize in a week, or even a month or, under the current circumstances, even a year.  I would like to get some sense for how to navigate it, though.  I ended up deciding to just order bare boards from one of the Chinese board houses because neither OSH Park nor DK Red can fab the design I inherited and I don’t feel like laying it out again.  I’ll report back what I learn from this exercise.

I have a JLC order coming, ordered on 4/8, Delivery is scheduled for 4/16.  No price increase that I could see.  I decided to  just place the damn order and let the tariffs fall where they may.  There is a chance that de minimis exemption is still in effect (maybe gone by May 2??).  My total order with shipping is $750ish. I'll pass the tariff on to my customers.  If they don't buy, then that was a life lesson.

[phil from seattle]

I think a week to get stabilized is very optimistic.  This is likely a 6 month or longer war.  Maybe 3.75 years.

As to the country of origin  -  My per board BOM includes at least $2 of non-chinese parts - UK, US, Korea, Japan.  Is there a way to declare this and be charged at the COO tariff rate?  Makes for some messy calculations