Miscellaneous

MISCELLANEOUS

  • IMPORTING CHILDREN’S PRODUCTS

    Question: Does anyone have any start up guidelines for importing children’s apparel / products?  Safety, testing, labeling, classifying? ************** First of all, know the Consumer Product Safety Improvement Act (CPSIA).  To that end, start here: http://www.cpsc.gov/en/Regulations-Laws–Standards/Statutes/The-Consumer-Product-Safety-Improvement-Act/ Every style must be tested for CPSC compliance by a CPSC-accredited lab, which includes testing for flammability, small parts/choking […]

  • ATTORNEY PRESENCE DURING CUSTOMS REVIEW

    Question: We are looking for guidance from companies that have had experience with CBP’s Reg Audit folks. Customs has notified us that they would like to “come in and review some of our entries”. At this time we have no knowledge of any particular issue that they might be looking at. In such a case, […]

  • ‘VISIBLE LINING’ DEFINITION-addt’l answers

    Question: Does anyone have a good definition of what Customs considers “visible lining”? ========== ADDITIONAL ANSWERS: From an apparel standpoint, visible lining is what it says: the lining (permanently attached) that is visible.  This would be as opposed to other linings inside a garment, such as interlinings (usually hidden behind a shell fabric facing if […]

  • CEE PARTICIPATION-addt’l answers

    Question: Our company is considering participation in a Center for Excellence and Expertise (CEE), but have some reservations. What are the benefits your company has experienced, and what (if any) are the potential risks/downsides of participation? Has anyone in the community had any negative experiences with a CEE? Your thoughts and comments are greatly appreciated. […]

  • ‘VISIBLE LINING’ DEFINITION

    Question: Does anyone have a good definition of what Customs considers “visible lining”? ========== Answer: I don’t know if this helps, but General Note 12 of the Tariff Schedule (NAFTA), Chapter 61 Rule 2 specifies the following regarding visible lining:   If the rule requires that the good must also satisfy the tariff change requirements for […]

  • HAND-CARRY PROCEDURE

    Question: I am struggling to write a procedure on how our Company should handle items that are being carried back from China. I have to educate employees and do it fast. 1)      This includes: Prototypes,   Samples ,  Parts samples & for production or resale Samples coming back can vary from a fabric sample to an […]

  • AIR FREIGHT SHIPMENT PROCESS

    Question: If anyone in the membership has a work instruction for shipping departments concerning international air freight for non-production type shipments ( engineering samples, chemicals, etc) could it be shared ? ********** Answers: If the goods will return to the U.S. and not remain overseas, then get a ATA Carnet. www.atacarnet.com for additional information.

  • PARTY ISSUING SHIPPING INVOICE

    Question: In the following scenario which party should be issuing the Canadian Customs invoice ? Shipper: Our company Sold to: US company Ship to: Canada company The Sold To party insists on issuing the cci as they do not want their customer to see the purchase price from us.  Who should be issuing the cci? […]

  • 7501 RELATED PARTY IDENTIFIER

    Question: We are related to our shipper, and use a courier for entry clearance. I am seeing different results when reviewing entries using the ISA review as a template. For informal entries, there is no relationship declared. Is this worth pursuing with the courier? Is it a  CBP concern? For informal and formal entries, there […]

  • HTS/SCHEDULE B FOR DOWNLOADED SOFTWARE

    Question: We are a multinational software company and like many other software firms the majority of our product is distributed electronically via internet downloads. Typically, software is classified based on the underlying medium (i.e. optical disk, magnetic tape, floppy disc, etc.) on which it is reproduced. Is anyone aware of a Schedule B number or […]

  • INCORRECT HTS CODE-addt’l answers

    Question: If we are aware that we have been mis-classifying imported parts for the past 5 years, should we switch to the correct code or wait until we thoroughly investigate internally and then file a Prior Disclosure? We typically use 8481.80.9085 for misc. valve parts since that is what we manufacture. We had a firm […]

  • USPPI IDENTIFICATION

    Question: Who is the USPPI in this domestic U.S. delivery scenario?….. Our German subsidiary sells Product X to a German customer (transaction #1).  Product X will be supplied from our U.S. factory. The German customer wants Product X delivered directly to their U.S. subsidiary, where the product will be tested for compatibility (but not modified) […]