• Products sent to customer for demonstration

    Question: I’ve done extensive research on 9801 and reviewed multiple rulings, and I wanted to ask for your insight on a specific scenario. We have products, both U.S. and foreign origin, that are shipped to customers strictly for demonstration purposes and returned within a year. These are not promotional samples, but actual equipment used to […]

  • Clarification on HTSUS 9801.00.10 Eligibility – “For the Account Of” Interpretation

    Question: I am seeking clarification on the eligibility requirements under HTSUS 9801.00.10, specifically the condition that goods must be “reimported by or for the account of the person who imported it into, and exported it from, the United States.” Our scenario is as follows: We operate in the clinical trial industry and manage the global […]

  • Manufacturer affidavits / functional responsibility for issuance

    Question: What FUNCTION in an organization issues a manufacturer’s affidavit typically (when requested by a company to support its 9801 claim)?   Trade Compliance?  Manufacturing?  Other? Answer 1: Hello, The FUNCTION that typically issues a manufacturer’s affidavit to support a 9801 claim is the Trade Compliance team, often in coordination with Manufacturing or Production teams.  While […]

  • 9801.00.10.12 usage

    Question: Fact pattern:  My US company buys goods from an OEM in Canada.  We re-sell/export those goods (as is)  to France. When they go bad, France customer sends them back to us in the US, and we then export them to the vendor in Canada for repair. Canada repairs, sends back to me in US […]

  • Chapter 98

    Question: We have several tools, classified in 8479.89, that we move back and forth between the US and Canada.  The country of origin of the tools is Canada.  The tools were imported into the US and exported back to Canada, within the last year.   When I bring these tools back to the US, can they […]

  • Return and Repair

    Question: I have a case where an Asian Air force returned an ECCN 9A610.x part prior to our advising them on using 9801.00.10. They marked the package “returned for repair” but if they used the tariff code for the part and not 9801.00.10 does that mean we cannot use 9801.10.000 (Schedule B) for the export […]

  • Use of HTS 9801.00.1012

    Question: Question for the community.  Original export was a 9A610.f piece of capital equipment exported last year on a BIS license to an Asian Air Force.  Now we have to bring back to the USA an ECCN 9A610.x component from that equipment for repair-and-return via license exception RPL (EAR 740.10). Do you recommend using HTS 9801.00.1012 […]

  • 9801.00.20

    Question: We buy product from a domestic supplier that imports the product from China and they pay the duties/tariffs, etc.  This cost is passed to us when we purchase the product.  We ship the product to various countries around the globe for temporary lease agreements.  When the product is returned, can we use the 98010020 […]

  • Use of 9801.00 Provision and USMCA

    Question: We will be producing, under contract, sizing vests for ballistic carrier fitting, in El Salvador. They are DR-CAFTA qualified goods. One of the options we are considering is the following: Import into the US from EL Salvador Transport for export to our IMMEX operation in Tijuana, MX. Our IMMEX operation will produce non-ballistic (dummy) […]

  • COO as US v. 9801

    Question: Hello ICPA community, My company’s goods, originally from the US and exported to a foreign country, are now returning to the US.  For internal reasons, we lack the export documents needed to import them under tariff number 9801 (US goods returned), so we have not used this provision. I want to propose that, instead […]

  • Blanket Foreign Shippers Declaration

    Question: A client of ours imports under 9801.00.1012 aircraft parts of US origin.  The foreign shippers are the actual airlines returning the goods to the US for repair.  Is it possible to secure a “blanket” foreign shippers declaration from the foreign shippers so that the document does not have to be sent for each and […]

  • Import Entry Exemption

    Question: Hello Member; My warehouse exported a wrong shipment to Argentina.  The shipment did not leave the custody of the carrier, nor was there an entry in Argentina.  Discovery occurred a few days ago and working on return to the USA. I asked our customs broker and did not know how to handle.   I visited […]