Miscellaneous

MISCELLANEOUS

  • IEEPA Refund Timing once an ACH Trace # is on ACE Report REV-603 & REV-615

    Question: a { text-decoration: none; color: #464feb;}tr th, tr td { border: 1px solid #e6e6e6;}tr th { background-color: #f5f5f5;} I’m looking to benchmark timing on IEEPA refund payments via ACH once an ACH Trace # appears in ACE reports (REV‑603 / REV‑615).Our current scenario: CAPE claim with multiple entries Liquidation date: April 23, 2026 Refund […]

  • Ruling HQ 344357

    Question: Does anyone have details about Ruling HQ H344357, which reclassifies metal and rubber automotive air springs and suspension bushings as auto parts under various HTS codes? Answer 1: HQ H344357December 16, 2025OT:RR:CTF:EMAIN H344357 SKKCATEGORY: ClassificationTARIFF NOs.: 8708.80.65; 8708.99.55; 8716.90.50ROBERT LEOMEEKS, SHEPPARD, LEO & PILLSBURY570 LEXINGTON AVENUE, SUITE 2405NEW YORK, NY 10022RE: Revocation of NY […]

  • Boilerplate verbiage for Protest for 180-day deadline approaching but not elegible for CAPE

    Question: We haven’t filed for IEEPA refunds in CAPE yet because of reconciliation.  Some of the entries have the 180-days-after-liquidation dates approaching, and we would like to file protests to hold them open.  As it’s likely a standard process, does anyone have boilerplate verbiage to use in the protests? Answer 1: Yes, I think that […]

  • Consignment Shipments – proforma vs. commercial invoice

    Question: Looking for exporters who ship to customers under consignment.Do you use proforma invoices? We typically have not and only supplied a commercial invoice, but we have a customer asking for a proforma until the goods are sold in country. Answer 1: Well that’s the definition of a proforma invoice, it’s for goods that are […]

  • Reconciliation and CAPE

    Question: I have not yet filed in CAPE because all of our entries are flagged for reconciliation.  My company is selling our IEEPA refunds and the buying company is asking us to file recon for all 2025 entries BEFORE the CAPE filing.  But I think that’s inappropriate. When we file recon, it all goes on a […]

  • Filing in CAPE for entries more than 180 days past liquidation

    Question: CBP says that we cannot file entries in CAPE that are under protest.  But if we’re approaching 180 days past liquidation, we need to file a protest to hold the “window” open.  So, what do we do with entries approaching 180 days after liquidation, and we’re not yet in a “phase”?Will CAPE accept filings […]

  • Buy America Act and a Maquiladora

    Question: We manufacture clamps from US sourced steel, but the manufacturing process takes place in Mexico by a Maquiladora.  Would those products be eligible for Buy America Act? Answer 1: Buy America has a clause for FTAs. However you need to find the BA Act rule to verify if I recall correctly.

  • Self-Filing Entries Question

    Question: Are there any self-filers in the group who use third-party couriers strictly for transportation while handling their own entry filings? I’m interested in understanding how common this approach is and whether others have had success with this process. Answer 1: I do this process, but I’ve had some difficulty consistently getting the entries turned […]

  • Plastic Tax Colombia

    Question: Colombian Customs created a new Plastic Tax to minimize plastic use, according to Resolution 000005 dated February 9, 2026, our customer must declare to customs the weight of single use plastic on their imports.Our cusotmer is also requesting that we fill out a Certification Letter declaring the weight for each delivery we made to […]

  • Broker Continuing Education Tracking

    Question: I’ve been tracking my own broker continuing education on a spreadsheet.  Is there a CBP portal where I can enter it as I go? Answer 1: There is no portal for you to enter as you go. Some people are using NEI for tracking their credits which is free. I use a spreadsheet and […]

  • VN COO Documents

    Question: We have an item we ship out of VN. And when the COO was issued, we were told that VN would not issue the COO with the tariff we believe is the correct tariff. They would only issue it with the tariff they believe is right. That seems extremely odd to me. VN not […]

  • Company Mergers Legacy Entries

    Question: We have a company that is merging in ours.  They will now by using IOR as one company going forward.  My question is what happens to that merging company’s prior Customs entries? Who is responsible if Customs were to do an audit on entries from that company prior to merging with us?  How’s does […]