QUESTION: What valuation method should be applied to the following scenario: China sells product to US Entity. For this example, lets say the unit value is $100. In some cases the China company is related. For this example, lets say they are not related. The product ships direct to Canada Entity which is related to […]

  • Customs valuation for returned inventory

    QUESTION: We are reassessing our inventory allocation globally.  We’ve found slow moving inventory in country X that is fast moving in the US. We want to bring this back to the US. Some has been sitting for a while and was about to be written off and destroyed so I. That market there is no […]


    QUESTION: We will be taking over the order book for an existing US company.  To fulfill these orders, we would purchase finished goods from China, S Africa &  Brazil that would become our inventory at an existing facility.  We would then re-sell this material to the end customer directly and pay a royalty of 3% […]


    QUESTION: We have a growing quantity of less-than-material-minimum-buy surcharges, that we declare as dutiable under supplemental payments (not assists). Current process: we the buyer direct the T1 seller to buy certain quantities of materials from certain T2 materials suppliers than are often below the T2 suppliers’ minimums.  The T1 seller pays the T2 for their […]


    QUESTION: We are going to be importing a product that will be assembled slightly differently than normal. Instead of our factory in Vietnam making/assembling the complete item. Our factory with make most of the item. Then send it to our 3PL in Vietnam, where the final piece will be installed. What is the recommended process […]


    QUESTION: My question relates to valuation on imports into the USA. Currently, a US company purchases steel products from a vendor in China and imports it into Canada. Then half of that product is sold to a related party in Canada at a 65% markup and the remaining half of product is shipped to the […]


    QUESTION: Company A is a US based company with a sister company (Company B) in Norway.  A purchase order was issued to Company A from a customer in Norway.  Part of the purchase order is that Company A in the US will ship goods to sister company B in Norway and customer will take from […]


    QUESTION: We are considering expanding our First Sale for Export (FSFE) program in light of the Section 301 tariffs and would like to do some benchmarking to see if other retails are doing the same. If your company participates in the First Sale program, do you handle within Trade Compliance department, work with your legal […]


    QUESTION: Time of determination of ‘price paid or payable’ Does anyone have the answer – and more particularly the CITATION to support the answer? *************** Add’l Answer: I am not sure of what you are asking here. In CBP ruling HQ H021399, April 29, 2011 it explains: Concerning whether the pro forma invoice price represents […]

  • Transaction Value

    QUESTION: A product is made in China, imported into CA, then sold & shipped to the US for $3.95. The party in Canada pays selling commissions to sales people in the US to sell the product; should the US selling commissions be included in the transaction value? *************** Add Answer: No. This is because the […]


    QUESTION: Like to ask the membership a question about software that is downloaded on to our machine once it has been installed at the international customer site. Because it is not being exported on our PC that controls the machine at time of export, do you remove that value from the commercial invoice, i.e. System […]

  • Correct value to be declared

    QUESTION: I have a question regarding what is the correct value to be declared on an import. Scenario- domestic company issues a p.o. to us (USA company), we issue a p.o. to our manufacturer in China. They ship the goods to the USA, to our clients door directly. Entry made under our name, for we […]