Miscellaneous

MISCELLANEOUS

  • CBP RECORDKEEPING FINES

    Question: Does anyone have an a real life example where CBP fined an Importer for record keeping non-compliance? ************* Answers: An importer was claiming duty-free treatment under HTS 9801 (US goods returned) on multiple imports.     Via Requests for Information, U.S. Customs requested  copies of the required Manufacturers Affidavits to support the use of HTS 9801.      […]

  • BROKER MANAGEMENT TEMPLATES

    Question: Does anyone in the membership have any of the Customs Brokerage management templates below: Service Level Agreement (SLA) Statement of Work (SOW) 3. Standard Operating Procedure (SOP) ************ Answers: SOP template below: http://www.icpainc.org/wp-content/uploads/2014/10/ICPA-Sample-Procedures-template.doc

  • SECTION 321

    Question: I am interested to know from the trade community their perspective on proposed legislation €œLow Value Shipment Modernization Act of 2015€ by which Customs may increase the value of Section 321 from $200 to $800? This bill was assigned to a congressional committee on February 13, 2015 for consideration. *********** ANSWERS: This will help […]

  • PURCHASED PRODUCT COMPLIANCE

    Question: I’m specifically looking for retailers because the business is unique to other types of importers and manufacturers but are there folks who can provide a snapshot of how they get information to classify items and where in the buying/shipping process that happens? For example, my current process is that the vendor/supplier provides a sheet […]

  • MID CODE CREATION

    Question: For MID code how would you handle parentheses ? ========== Answers: Attached CBP guidance which may be helpful http://www.icpainc.org/wp-content/uploads/2014/10/MID-Construct.pdf ========= Ignore them – as per the general rules to construct a manufacturer code…. http://www.icpainc.org/wp-content/uploads/2014/10/MID-configuration.pdf ========== Characters such as hyphons, periods, commas and parentheses are disregarded when creating an MID. ========== http://www.cbp.gov/sites/default/files/documents/CBP%20Form%207501_Instructions.pdf 7501 Appendix 2 […]

  • 520d PROCESS

    Question: Many of our products are manufactured in our Maquila operations in Mexico. Because products in chapter 94 generally do not tariff shift, we need supplier NAFTA certifications to qualify our products. It appears that it is a routine expectation that we will never have all the supplier certifications early in the new year. We […]

  • SPLITTING BOL AFTER SAILING

    Question: Here’s a new one, on me at least; we have a shipment to China where the customer cannot pay for the full amount of the goods (shipping in 3 containers).  So they want us to re-consign 1 ½ containers to another, related party (related to them).  Has anyone ever done this before?  Is it […]

  • DUTIABILITY OF CUSTOMS FEES

    Question: Upon return of items that have been repaired/re-worked in Germany, our supplier has added a line on the commercial invoice for “Import Customs Fees”.  I have been told that they are charging our company back for import fees/duties that are applied when the items ships to Germany.  They separate the line on the commercial […]

  • CHEMICAL SAMPLE IMPORTING

    Question: As an importer of chemical samples, we want to be 100% compliant with all requirements under DOT/IMDG/IATA/OSHA, etc. and the new GHS label initiative. To effectively do that, our product compliance team conducts an extensive review which includes an evaluation of supplier labels, often resulting in several days of email dialogue.  Due to this […]

  • ON-SITE BROKER REVIEW

    Question: Can the membership provide guidance of what an on-site visit to a customs broker facility for purposes of auditing the customs broker consist of?  What would the agenda look like? ************** ANSWERS: I would start with A meet & greet of all associates assigned to work on your account Broker to provide a clear […]

  • GLOBALIZING HTS CODES

    Question: I’m just wondering if any of the members have encountered foreign governments insisting that their products are classified using different tariff numbers than the U.S., making the HTS anything but harmonized?  For example, we manufacture Integrated Circuits which have always been classified as 8542.  We have a new product that we applied for a […]

  • APPAREL TERMINOLOGY

    Question: The terms artificial, synthetic and man-made all appear very close and can’t find a good set of definitions in the tariff, explanatory notes or informed compliance publications. Does anyone have a key of what fabrics fall under which provisions ? ************** Answers: When I was taking the broker exam, I did not classify apparel […]