• Dept. of Commerce Scope Ruling

    Question: Can anyone from the group explain the process of how to submit a scope ruling to the department of commerce for an AD/CVD determination? Also, e-mail to send the request and how long it takes? Answer 1: Be very careful on this.  The petitioner will be given an opportunity to submit comments, most likely […]

  • CBP binding rulings

    Question: I’m curious what the membership thinks:   We filed a for a ruling.  CBP issued the ruling but we don’t like it, so we’ve filed a request for reconsideration by HQ.  Knowing that a reconsideration can take months if not years, and assuming we get a favorable ruling from HQ, what is the best way […]


    QUESTION: We are going to import a product calls Docking Monitor. We found this HTS # 8528.52.0000 is used to classified for a Monitor. The docking monitor has the following: USB Type-C port for docking an HP notebook or HP desktop mini Single power button on the monitor to turn the monitor and docked notebook […]


    QUESTION: We submitted a written ruling request via courier with a sample almost 2 months ago. I know the package was received, but I have not received anything from CBP. Usually we receive an answer within 30 days. Has anyone in had a similar delay? Is there a way to follow-up on written requests? *************** […]

  • Binding Rulings

    QUESTION: Is there any risk to requesting a binding ruling besides the obvious of being bound to follow the ruling? **************** Answers: I think it’s the best thing to do. It gives you a sense of security and consistency. A lot of people don’t like to use rulings as part of their trade compliance program […]


    QUESTION: Who usually applies for CBP classification rulings? Is it Corporate or the Business Units? According with the definitions,  Is applying for  a ruling considered “corporate compliance activity” or is it “Customs Business”? ================= ANSWERS: The first question to ask yourself is, are the “Business Units” separate legal entities (such as subsidiaries)? If they are […]


    QUESTION: Can someone provide an explanation on how the classification determination of 4911 made in NY N300649 is correct in light of Section VII note 2? Except for the goods of heading 3918 or 3919, plastics, rubber and articles thereof, printed with motifs, characters or pictorial representations, which are not merely incidental to the primary […]

  • CBP Advance Ruling

    QUESTION: Does anyone know if advance rulings from CBP expire? We have couple of them from 2011, I’m wondering if I need to request an updated version??Your thoughts will be greatly appreciated. =================== ANSWERS: They do not expire.  However, they can be revoked if CBP determines that the initial ruling determination was incorrect. ================= A similar […]

  • Binding Ruling

    QUESTION: Scenario: A  Binding Ruling is issued to company “A” , and company “A” is subsequently acquired by company “B”. Company “B’ subsequently undergoes a name change to company “C” Would companies “A”, “B”‘ and “C”  be considered the same “person” for purposes of Binding Rulings issued under  19 CFR 177 ? In other words […]


    QUESTION: What has been the membership experience in general with Internal Advise recently. CEE or I.S at the port level? IA or Ruling? *********** Answers: Rulings are only for prospective transactions; Internal Advice (IA) is for issues currently with CBP at the port level, which for your purposes would include CEE. See 19 CFR 177.1.  […]


    QUESTION: I need to request a ruling that has nothing to do with classification, marking, origin or application of trade program or trade agreement, which are the only options on’s eRuling site. We are an LLC company. Our primary broker (mandated by our headquarters in Germany) is requiring us to sign a new POA […]

  • Foreign Supplier Binding Ruling Request

    QUESTION: Are foreign suppliers able to make a binding ruling request to U.S. Customs for their products that will be imported in to the U.S.? ********* Answers: Yes. George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 Direct: (415) 288-0428 Cell: (415) 254-5986 Firm: (415) […]