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January Due Diligence

An annual customs review is a good business practice. Another good practice is to make sure you are taking advantage of regulations that allow importing on a duty free or preferential basis. Here are a few basic items for your annual customs review.

 Contact mitch@52.91.45.227 if you need help.

Classification– review annual updates to Harmonized Tariff to make sure your codes and descriptions are accurate. Proper classification and valuation of imported goods are the first step in compliance. If you do nothing else, do this.

Duty Drawback– this is a refund of duties paid on imports that are later exported. As supply chains expand there may be new opportunities for drawback. Record keeping is key here.

Chapter 98 of the Harmonized Tariff allows duty free entry of certain categories of goods. Examples are: American Goods Returned, American Goods Repaired or Altered Abroad, and American Components Assembled Abroad.

Trade agreements– programs which allow duty free or reduced duty rate entries. There are many agreements (such as USMCA) in place.

Customs rulings– consider requesting formal customs rulings prior to large transactions. This ensures compliance and eliminates uncertainty about imports. Rulings can be requested thru the CBP website.

Correcting errors– when an entry mistake is discovered it can be corrected by a prior disclosure to CBP. The formal process is a Post-Entry Amendment/Post Summary Correction. A prior disclosure can help mitigate penalties.

So you want to be a Customs Broker ?

Congratulations to all who passed the October 2020 Customs Broker exam. To those who came up short give it another try in April. The test is difficult and passing rates are typically in the 10-12% range.

Here are a few questions from the exam. Answers below.

  1. What are the Customs Territories of the United States?
    A. The states, District of Columbia, and the Commonwealth of Puerto Rico
    B. The states, Virgin Islands, and the Commonwealth of Puerto Rico
    C. The states, District of Columbia, Virgin Islands
    D. The states, District of Columbia, the Commonwealth of Puerto Rico, Virgin Islands,
    American Samoa
    E. The states, Commonwealth of Puerto Rico, Virgin Islands, American Samoa, and island of
    Guam
  1. Cotton napkins are imported into the United States. The cotton fabric comprising the
    napkins is woven in China and the sewing thread is made in Taiwan. The fabric and thread are
    shipped to Vietnam to be cut, sewn, and finished into the napkins. The finished napkins are then
    shipped in bulk to Singapore for packaging before being imported into the United States. What is
    the country of origin of the napkins?
    A. Vietnam
    B. China
    C. Taiwan
    D. Singapore
    E. United States
  1. Which of the below drawback periods is CORRECT?
    A. Drawback is permissible on exported or destroyed merchandise, which was imported,
    sold at retail, and returned to the importer, within 3 years of the date of import
    B. Unless a waiver is applicable, a Notice of Intent to Export, Destroy, or Return
    Merchandise for Purposes of Drawback (CBP Form 7553) must be filed with CBP at
    least 15 working days prior to the date of intended exportation
    C. At least 10 working days before the intended date of destruction of merchandise under
    CBP supervision, upon which drawback is intended to be claimed, a Notice of Intent to
    Export, Destroy or Return Merchandise for Purposes of Drawback (CBP Form 7553)
    must be filed
    D. A party may challenge a denial of an application for certification as a participant in the
    drawback compliance program by filing a written appeal within 30 days of the issuance
    of the notice of denial
    E. Drawback is allowed on imported merchandise if the merchandise is exported or
    destroyed within 3 years of the date of importation and was not used within the United
    States.

Answers: 26-A, 27-B, 63-D

LinkedIn Post

Here’s a shout out to Mike Allocca for a good refresher on classification and in depth discussion of General Rules of Interpretation (GRIs).

Maine International Trade Center3,512 followers2w • 2 weeks agoWho is responsible for correct HTS and Schedule B classifications? Don’t miss our live webinar with Mike Allocca on Nov. 17th. Learn more and register today!Harmonized Tariff Schedule and Schedule B Classification – Maine International Trade Center