QUESTION: I have an inquiry about customs valuation for rental goods. The WTO Customs valuation agreement is built upon sales of goods with the different customs valuation methods. However, there is no guideline how to calculate goods for rental within this agreement. What I mean is renting out, for example, trackers together with packaging, never […]


    QUESTION: Is there a good resource to identify which countries include or excluded transportation costs in their dutiable value? *************** Answers: I asked myself the same question a few years ago.  I am no aware of one source of the truth about this.  I have learned though, that most countries base dutiable value on the […]


    QUESTION: Safety Training materials including manuals and placards and includes virtual training from outside the US.  All of the items are priced separately including the virtual training. Is the virtual training a part of the Customs value when importing the training materials?  If yes, is it pro-rated over the goods which fall in different tariff […]

  • First Sale evaluation

    QUESTION: We source most of our goods from our plant in China, but also have other suppliers in China and other countries.  We are looking for duty savings opportunities and beyond duty drawback (which we are participating) would like to look at First Sale.  Would the other suppliers need to be distributors as opposed to […]

  • Valuation with commodity surcharge adjustments

    QUESTION: We are looking at implementing a surcharge program with 2 of our suppliers in China. The premise is that we will be paying a base price with each purchase order but then adjusting based on a quarterly average for aluminum and currency.  We could be receiving either a debit or credit from these suppliers […]

  • Assembly Price/Valuation

    QUESTION: We have new business of where we would consign parts to foreign supplier, who will then assemble and then ship/import to US to our company. In reviewing customs valuation / encyclopedia, is the correct valuation as follows? Cost of Components + Assembly Fee = Import Valuation For cost of components, this would be the price […]


    QUESTION: We have imports on DAP (US warehouse location) which includes our contracted ocean rate built into the cost of the product.  After reviewing the regulations and CBP’s ICP on freight deductions, I do not believe is it acceptable to use the contract’s rate because that may not be the actual cost of freight.  Moreover, […]

  • Is the value of ‘core’ deductible?

    QUESTION: Does anyone have experience with deducting the value of ‘core’ when importing automotive batteries, or similar items that contain core,  using transactional value? If so, what type of documentation or information is required to support this type of deduction? =========================================================== ANSWERS: Quite the opposite…I have the experience of ADDING the core value to imported […]


    QUESTION: I need to figure out the correct value for import of a replacement product under warranty. Company A imports the finished good from a related party, if the good turns out to be defective then under the warranty the related party sends them a replacement good. So it isn’t that they send out the […]


    QUESTION: A parent company in the USA has a subsidiary in China that manufactures finished goods and ships them to the parent company.  As the parties are related, the finished product includes a markup for profit. The subsidiary in China also provides the parent company with purchased parts to be used in the manufacturing process […]

  • Customs Valuation – Intra-company

    OT Fact Sheet: Origin Certification Requirements QUESTION: Our company moves material from the US to Europe for storage at a local European Warehouse. From there we fulfill sales orders to various customers within the EU. The move is considered an intra-company move internally so no real sale is involved on the movement from US to […]