• Engineering Service Fee

    Question: My commercial invoice has a fee for “technical services” and a charge. The technical service is drafting, design and engineering and I pay the fee to the manufacturer. This is separate from the cost of the product I am importing, so one line for value of the goods and a second line for engineering […]

  • First Sale Valuation for Produce

    Question: Can anyone advise any risks and warnings that would disqualify the following scenario an importer of produce/vegetables from using First Sale Rule valuation with customs?  The Grower/Producer (is not the exporter) and sells to → Supplier (Foreign) Supplier (Foreign) creates a Pro-Forma Invoice for Customs purposes → containers are shipped to US imported under […]

  • Commissions – Valuation Question

    Question: Scenario:   Company A imports product for another company.  They are the importer of record, send the payment to the shipper, pay commission to an agent. Then they sell the product to Company B at a profit. However, ALL import costs and commissions are billed back to Company B.  The value of the commissions passes […]

  • Foreign Inland Freight Deduction- FCA Terms

    Question: We are a US importer who buys apparel from our foreign related entity. We buy the goods using “FCA Supplier’s Facility” terms. The US importer arranges to have their elected forwarder to pick up the shipment at the supplier’s facility and handles all the costs/risks from there, which includes the foreign inland freight (same […]

  • Import Value

    Question: In the wake of drastically increasing tariffs, would one be in violation of any regulation if we negotiated a lower profit margin with our suppliers in China, thus decreasing the import value from what the product was before?  For example, if they previously had a profit of 15% and we negotiated down to 8%? […]

  • First Sale for export

    Question: Has anyone had experience with the First Sale for Export (FSE) rule?  What specific documents does the importer need to comply with this rule? As the importer, we issue the purchase order (PO) to the foreign vendor under EXW terms. This vendor acts as the middleman or owns the factory. Currently, the middleman provides […]

  • Export Value

    Question: Thanks to the membership in advance.   In 15 CFR 30.6(a)(17) Census requires adjustment to the selling price for inland or domestic freight, insurance, and other charges to the U.S. port.  I would appreciate if members would share some best practices for practical implementation of this requirement, such as: how you calculate; how and where […]

  • Discounts

    Question: What is everyone’s thoughts on claiming a discount?  I’ve worked for a couple different customs house brokers, and they all seem to have different thoughts on discounts the last one hour for really would not claim any sort of discount, so I really wanted to get everyone’s thoughts on claiming a discount. Asked by: […]

  • Discount on proforma invoices

    Question: Hello ICPA, I have the scenario related to discounts in valuation.  Shipper and IOR are related, but product is being sold to US third party directly. Some proforma invoices contain a customer discount (customer specific), discounted from the value of the merchandise. Example: Line item value $1,300, discount $ 180, total invoice value $ […]

  • Shower Enclosure

    Question: We import shower enclosures with glass panels, aluminum frame and a fiberglass shower pan.  This is imported as a complete shower kit, all of the parts to assemble included. Two questions for the group. There are two bonding rulings, N304708, Tariff number: 7610.90.0080 and N248690, tariff number 7013.99.2000, which one is the better tariff […]

  • Testing costs for imports

    Question: Do testing costs have to be included in the FOB value for imports?   We are looking to pay them separately, rather than include in the FOB cost, and are not sure if Customs would have an issue with this. Answer 1: It depends on to whom the the importer is paying the testing fee. […]

  • Reduced cost

    Question: Company A located in the US is offered a reduced price to purchase excess stock from a vendor in China. The reduced value will be 80% of what is typically paid.  If CBP were to question the valuation, what would be a reasonable explanation for the lower cost shown on the invoice?  In some […]