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Procurement Planning

Tariff Resources

University of Houston, Tariffs on Foreign or International Purchases, as of 2/18/26

  • Why This Matters

    • Tariffs can significantly increase the cost of internationally sourced goods. At the University of Houston (UH,) the department making the purchase is responsible for paying any tariff-related costs, with no central fund available to offset these costs. This makes understanding the process critical for budget planning and cost control.

  •  Key Highlights

    • Determining Responsibility: Vendors typically pass tariff costs to buyers. At the University of Huston, the requesting department is responsible for all tariff related costs. Departments must plan accordingly when budgeting for international purchases.
    • Vendor Communication: Departments should confirm key details with vendors before agreeing to any tariff-related increases, including the country of origin, the specific tariff applied, and potential sourcing alternatives.
    • Contract Protections: If a purchase order (PO) or contract were already executed, vendors typically are required to honor the agreed price unless the agreement specifically allows for tariff adjustments. Departments should not approve price increases without prior Purchasing review.
    • Negotiation Strategies: Prior to finalizing prices, departments may negotiate removal or reduction of tariff charges with vendors. In cases where a vendor insists on adding substantial tariff charges, departments are encouraged to explore alternatives—such as finding new suppliers sourcing in the United States.

    • Special Exemptions: Certain educational, scientific, and cultural imports may qualify for duty-free entry through the ITA-338P form, REQUEST FOR DUTY-FREE ENTRY OF SCIENTIFIC INSTRUMENTS OR APPARATUS process, potentially saving significant costs for eligible purchases.

  • Overview: Items Eligible for ITA‑338P Duty‑Free Exemption
      • To qualify, an import must meet all regulatory criteria for educational, scientific, or cultural use and be used for research or instruction in a public or private nonprofit institution established for educational or scientific purposes. Eligible items generally include:
    • Scientific Instruments or Apparatus include specialized equipment used for scientific research or measurement not available from a US manufacturer with equivalent scientific performance or capabilities and required for research or instruction.
    • Educational and Cultural Materials/Equipment/Apparatus 
      • The Florence Agreement includes “Annexes” that denote goods that if tariffed an exemption may be filed.
  • Regardless of category, all items must also meet these criteria:
      • The applicant must demonstrate that there is no equivalent U.S. made instrument.
      • The applicant must demonstrate that U.S. alternatives do not meet the required scientific performance.
      • Must be used solely for educational, scientific, or cultural work. 
      • Must be properly documented

-  Technical specs
-  Manufacturer details
-  Written justification of no domestic equivalent

    • Departments should confirm key details with vendors before agreeing to any tariff-related increases. These details include:
      • Product identification and description
      • The Harmonized Tariff Schedule (HTS) code classifications for each item being purchased. (NOTE: certain items could have additional tariffs associated with them, such as steel, aluminum, copper, automobiles or auto parts.) See link below.
      • Which entity is the Importer of Record (IOR) (buyer or seller)
      • Country of origin
      • Country of manufacture
      • From where the items will be shipped
      • Shipment Mode (air, ocean)
      • Any potential sourcing alternatives
      • Recommended Shipping Term: Delivered Duty Paid (DDP)
      • International Commercial Terms (Incoterms) are a set of rules that define the responsibilities, costs and risks involved in international trade transactions. If the item to be imported is not exempt from tariffs, the recommended shipping term is Delivered Duty Paid (DDP).  If DDP is invoked, the seller handles all logistics, pays all costs, taxes and duties related to import clearance.  The seller assumes all risk until the goods are received by the buyer. If the incoterms are not DDP, then UH (IOR) is responsible for paying the duties and taxes that the U.S. Customs and Border Protection levies.

  •  ITA-338P Form and Process

    • Certain educational, scientific, and cultural imports may qualify for duty-free entry through the ITA-338P form process. 
    • Before filing the exemption, notify Purchasing to ensure that the correct shipping terms are included on the Purchase Order and that the UH customs broker, CEVA Logistics, is notified.
    • Confirm Eligibility: Verify that the institution and the specific instrument meet the criteria, particularly that no U.S. made equivalent is available to meet the required scientific performance.
    • Obtain Information: Work with the foreign manufacturer/supplier to get the Harmonized Schedule of the United States (HTS) code and a detailed technical description of the equipment and its accessories.
    • Use HTS Code 9810.00.6000: This code specifically covers instruments and apparatus that are not manufactured in the U.S. and are intended for use by nonprofit institutions.
    • Complete Form ITA-338P: Fill out the "Request for Duty-Free Entry of Scientific Instruments or Apparatus" form. The form requires a detailed description of the instrument's intended use and documentation of efforts made to find a domestic alternative.
    • Submit Application: Mail five copies (one with an original signature) of the completed form and supporting documents to U.S. Customs and Border Protection (CBP).
    • Track and Follow-up: Federal processing can take six to eight weeks or longer. The application will be published in the Federal Register for public comment, and a final decision will be made by federal authorities.
    • Customs Clearance: The applicant must ensure the customs broker or official responsible for the purchase has a copy of the entry summary (CBP Form 7501), once the instrument enters the U.S. (Again, Purchasing recommends using CEVA Logistics.)
    • Paying Duties Upfront: Due to processing delays, the purchaser may need to pay applicable tariffs to receive the equipment and then attempt to claim a refund if the waiver is eventually granted.

  • Resource Summary