Here is a notice posted on the 2021 Harmonized Tariff Schedule. Except as noted there is no need to toggle between HTS codes for imports and Schedule B codes for exports. Exporters may use HTS codes in place of Schedule B. Go to https://hts.usitc.gov/current and choose the view tab.

Harmonized Tariff Schedule of the United States (2021)
Annotated for Statistical Reporting Purposes

NOTICE TO EXPORTERS
Through this notice, this HTS publication may be used in place of the reporting codes of Schedule B for reporting exports on the Shipper’s
Export Declaration or under the program for electronic reporting of exports. Except as noted below, the statistical reporting numbers (with
the article descriptions and units of quantity) for articles falling in Chapters 1 through 97 may be used in place of those in Schedule B. The
special prefix symbols which denote special tariff treatment should not be included. The following provisions are applicable for export
reporting purposes in lieu of the corresponding provisions in the HTS:
Description S

Contact mitch@52.91.45.227 for immediate assistance.

Canada Border Services Agency (CBSA) has updated their Customs Tariff for 2021.

Canada is the United States’ largest trading partner for exports and 3rd largest for imports. Here is a link to the Canada Customs Tariff 2021. For 10 digit harmonized codes, the first 6 are universal and the last 4 differ from country to country.

https://www.cbsa-asfc.gc.ca/trade-commerce/tariff-tarif/2021/menu-eng.html

CBSA maintains a robust, user friendly website. Here are several links that may be helpful for traders:

https://www.cbsa-asfc.gc.ca/agency-agence/program-eng.html

https://www.cbsa-asfc.gc.ca/export/guide-eng.html

https://www.cbsa-asfc.gc.ca/import/guide-eng.html

https://www.cbsa-asfc.gc.ca/import/courier/lvs-efv/menu-eng.html

Happy New Year!

January is a good month to review harmonized codes. The United States International Trade Commission has updated the Harmonized Tariff Schedule of the United States effective January 1, 2021. There are numerous HTS code revisions with the change record totaling 37 pages.

Using obsolete codes can result in customs delays, inaccurate  duty assessments, or fines and penalties, so it is a good business practice to check the tariff.

While you are at it are you sure EAR99 and NLR apply to your exports? Don’t assume, verify.

For assistance contact mitch@52.91.45.227

Last week’s post included Licensing FAQs for exporters. The licensing decision starts with ECCN (Export Control Classification Number). Here is another good resource from the BIS website. For immediate help contact mitch@52.91.45.227

https://www.bis.doc.gov/index.php/all-articles/47-about-bis/newsroom/506-export-basics-publications-2

As follow up to last week’s post here is a useful tool for exporters from the BIS website:

https://www.bis.doc.gov/index.php/documents/pdfs/286-licensing-faq/file

While assisting a client this week they made a common, but inaccurate, assumption that if their commodity is classified for export as EAR99 then NLR (No License Required) automatically applies. Not necessarily.

Here is some info from the BIS (Bureau of Industry and Security) website:

What does EAR99 mean?

If your item falls under U.S. Department of Commerce jurisdiction and is not listed on the CCL, it is designated as EAR99. EAR99 items generally consist of low-technology consumer goods and do not require a license in most situations. However, if your proposed export of an EAR99 item is to an embargoed country, to an end-user of concern, or in support of a prohibited end-use, you may be required to obtain a license.

Contact mitch@52.91.45.227 for assistance

Posted on LinkedIn

Questions about USMCA?
Good resource for traders….U.S. – Mexico – Canada Agreement (USMCA)cbp.gov

New mandatory EEI filing requirements effective 9/27/2020. Here is one of the the FAQs from the BIS website.

Q28: Are exporters required to file EEI for shipments of commercial items valued under $2,500 if destined to China and it is for commercial end use?

A: Yes. The new mandatory filing requirement in Section 758.1(b)(10) applies to all items that have an ECCN and are destined to China, Russia, or Venezuela, regardless of value, end use or end user. The only one of the exemptions in Section 758.1(c) that is available to overcome this requirement is License Exception GOV.

Need help? Contact mitch@52.91.45.227

The United States International Trade Commission has updated the Harmonized Tariff Schedule of the United States effective July 1, 2020. Mid year is a good time to review your harmonized codes. The change record for this revision includes 4 pages of newly established, modified, and discontinued codes.

Using obsolete codes can result in customs delays, inaccurate  duty assessments, or fines and penalties so it is a good business practice to check the tariff. While you are at it are you sure EAR99 and NLR apply to your exports?

For assistance contact mitch@52.91.45.227

When updating clients’ inventory and parts lists questions about country of origin come up regularly. Country of origin, often abbreviated COO, is one of the elements, along with harmonized code and commodity valuation, in determining duty/tax rates. While trade agreements such as NAFTA (now USMCA) have specific and complex rules of origin, the basic COO elements are:

Country in which the commodity is made, mined, grown, manufactured, or underwent substantial transformation. The 3 way test for substantial transformation is new name, new character, new use.

Substantial Transformation Rule….used to determine country of origin if articles or components are not wholly obtained from one country…Does article have new name, character, or use?

• Change in character- altered physical characteristics of article or components. Were changes cosmetic? What was the process that resulted in change?
• Change in use- Is end use of article interchangeable with end use of components? Is end use of component predetermined at time of importation? What was the process that resulted in change of use? Predetermined end use generally precludes substantial transformation but subject to specifics of article/components in question.
• Change in name- this is the least compelling of the factors supporting substantial transformation. Do components retain original name after processing?
• Subsidiary/Additional Factors- extent and nature of operations (complex or simple); value added and/or cost incurred during transformation process; essential character of article (components transformed into finished product); change from producer to consumer good; tariff shift.

Ad Hoc Logistics can help with regulatory questions or your international logistics needs. Contact mitch@52.91.45.227