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 cbp.gov’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 […]
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) […]
QUESTION: As we do our classification work, we will review the rulings issued by CBP to understand what they think about certain goods. In the end, we will use rulings to help support the classification. However, rulings get revoked. The only way I have found to look for revoked rulings is through the Customs […]
QUESTION: I have a binding ruling from customs about an LED module that they classified as 8543.70.7000. That is no longer a valid HTS code. Should I use 8543.70.7100 or because there is a new LED HTS code for Lamps 8539.50.0090? I would think it would just change to 8543.70.7100 but because it is LED […]
QUESTION: I have a binding ruling from customs about an LED module that they classified as 8543.70.7000. That is no longer a valid HTS code. Should I use 8543.70.7100 or because there is a new LED HTS code for Lamps 8539.50.0090? I would think it would just change to 8543.70.7100 but because it is LED […]
QUESTION: Would writing for ruling requests be considered a Corporate Compliance Activity or Customs Business? ========== Answers: Ruling = Classification = Customs Business ========== Absolutely. A request for binding ruling is a regulatory process governed by the Administrative Procedures Act. ========== Read Part 111.1. sounds as if filing a customs ruling is considered customs business […]
QUESTION: I submitted a classification ruling request to CBP for an injection molded part that we import. In the past it has been imported under 2 different HTS codes depending on the finished product that it will be used in. If CBP provides a different HTS than we used, do we need to file an […]
QUESTION: On CROSS the text of this ruling is truncated. https://rulings.cbp.gov/detail.asp?ru=h215555&ac=pr Does anyone perhaps have the full text? ====================== ANSWERS: Click on the Word icon on CROSS and the entire ruling will be downloaded onto your computer. ====================== You have to click the light blue “W” in front of the ruling number to download […]
QUESTION: Has anyone in the industry experienced longer than usual delays in getting responses to classification ruling requests from CBP? With the exception of goods that have to go to the lab for testing, we have recently experienced wait times up to 90 days for both electronic and mail-in requests. We noticed the CBP website […]
QUESTION: Does anyone have a format they use to write a ruling request? Also, how do you know which Customs office to send it to? ========== Answers: Rulings can be requested online through the eRulings portal, you can access it from this page along with a lot of good information on formatting and what to […]
