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All Textiles and Apparel May Be Imported from Cuba but High Duty Rates Remain

As of 22 April persons subject to U.S. jurisdiction may import coffee (HTSUS heading 0901) and additional textiles and textile articles (wool and cotton fibres, yarns and woven fabrics of HTSUS Chapters 51 and 52) produced by independent Cuban entrepreneurs in addition to the items previously authorised, which include apparel of Chapters 61 and 62, made-up textiles of Chapter 63, and textile products of Chapters 53 through 60.  As a result of this action, there are no longer any textile or apparel products on the U.S. State Department list of goods not eligible for importation from Cuba.

Those importing authorised goods or services from Cuba must obtain documentary evidence demonstrating the entrepreneur’s independent status, such as a copy of a licence to be self-employed issued by the Cuban government or, in the case of an entity, evidence demonstrating that the entrepreneur is a private entity that is not owned or controlled in whole or in part by the Cuban government. State notes that third-party verification of such status by an independent organisation may suffice in the future.

Before considering the possibility of importing from Cuba, U.S. companies must keep in mind that Cuba remains one of two countries (the other being North Korea) still subject to column 2 duty rates in the Harmonised Tariff Schedule of the United States. This means that apparel imported from Cuba is subject to duty rates as high as 90 percent and no lower than 25 percent.

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