Question: We are willing to compensate our suppliers for increased import duties due to reciprocal tariffs and Sect 232. We ask for proof first, ideally a redacted 7501. What if they refuse to provide even a redacted 7501? What can we accept as proof? Some have tried to send just their broker’s invoice for the […]
Question: We currently have all entries cleared under our basic importer number ending in suffix “00”. We would like to start clearing another division’s entries under an importer number ending in “AB”. On entries, and on the 5106, do we show the corporate HQ address or the division’s address? Answer 1: There is room for […]
Question: My broker told me that the trains (locomotives, train cars) we build and ship are NOT vehicles as contemplated by HTS US 8544.30, so our ignition wiring sets are somewhere else in 8544. Where can I find a definition of “vehicles” for this purpose? Answer 1: Chapter 87 specifically covers “Vehicles other than railway […]
Question: Is anyone noticing an increase in delivery times on small package imports? If so, have you recommended Supply Chain increase their lead time for small package and if so, but how many days? We’ve noticed a recent increase in our delivery times. Shipments will show cleared Customs, and out for delivery for multiple days […]
Question: Hello ICPA Membership– Can anyone provide a USDA Guideline 1100 letter template for FDA-approved, finished pharmaceutical products? Further, is a USDA letter required for products that have no animal origin? The way I read the guideline is that a letter is only required if the pharmaceutical product has animal origin. How is this notated […]
Question: Does anybody in the membership have a First Sale SOP and/or checklist they can share? Many thanks. Answer 1: To qualify for First Sale, please ensure the following: Goods Must Be Clearly Destined for the U.S. The first sale must be for export to the United States, and this intent must be documented at […]
Question: We manufacture a particular kind of vehicle. Sometimes, we create a mockup of that vehicle (not functional, purely for demonstration purposes) out of steel, plywood, and plastic. We’re comfortable that this is covered by 9023.00. Our question is, how do we compute value of that mockup? Cost of materials plus labor? There’s no technical […]
Question: Some sources are saying “protest everything that’s even close to liquidation” and some are saying “CBP isn’t allowing any IEEPA-related protests.” So, which is it? What are YOU doing? I’m tracking liquidation dates and just waiting to see what happens. Should I be doing more? Answer 1: I think that you are getting inappropriate […]
Question: Is there any way to get our commercial invoice number listed on the 7501 (and thus populating a field for ACE reporting)? Answer 1: There is no way in ACE to record and report on Importer-specific data references like PO# or Invoice# or Style#. You can require your broker to maintain this level of […]
Question: If I have a good that would qualify under the USMCA but also has a steel derivative HTS. Sect 232 still applies to the steel content and USMCA to the remainder? Answer 1: Section 232 duties are not waived for USMCA goods. See below for CBP FAQ on Section 232. Section 232 Tariffs […]
Question: If I have a $20,000 piece of equipment all made from US steel except for a $17 metal part from Belgium. I have to declare the Belgian part separately and pay 50% Sect 232 just on the $17, right? There’s no de minimis value threshold for derivatives. Answer 1: As you described your […]
Question: If I have a component that can be used on either a self-propelled railcar or a non-self-propelled railcar, do I have to classify it by use? Not Self-Propelled would be 8607.99.1000 and Self-propelled would be 8607.99.5000. We ask because Sect 232 applies to 8607.99.5000 but not (yet) to 8607.99.1000. We’re wondering if we can […]
