• COO Labeling Parts used in Production

    QUESTION: What are the COO rules as they apply to parts my company produces that are used ONLY in production of finished goods?  That is, they are not sold or re-sold to customers directly. I discovered that parts we’re producing in Europe did not have COO in system (I’ll address that myself), but COO is […]

  • SEC. 321 RELEASE FROM FTZ

    QUESTION: Does anyone in the membership know if Section 321 entry can be claimed on withdraws from an FTZ? If I understand correctly, most Section 321 entries are filed by carriers. In case of FTZ, normally who files for Customs release? FTZ operator or carrier? Is ACE ready for brokers to file Section 321 entries? […]

  • ACE BOND SUFFICIENCY REPORT

    QUESTION: What is the best ACE report for sanity check on sufficient bond amount?? ========== Contact your bond writer for a report, it’s a lot easier. ========== Any of the Entry Summary reports would work depending on how detailed you want to get (ES-7008 perhaps) – but don’t forget to factor forward based on the […]

  • Miscellaneous Tariff Bill – HTS Codes

    QUESTION: Does anyone have a list of the tariff numbers that will be impacted by the miscellaneous tariff bill 2018? ========== Answers: Attached is the link to the version passed by the Senate. https://www.congress.gov/115/bills/hr4318/BILLS-115hr4318rfs.pdf ========== Here is the full list of MTB HTS codes. http://www.icpainc.org/wp-content/uploads/2014/10/Copy-of-MTB-2018.xlsx ========== Hi, Attached is a spreadsheet showing the HTS, MTB […]

  • NAFTA SOLICITATION SCENARIO

    QUESTION: Topic: Annual solicitation and factories I’ll start with giving the context for my new company: 30+ years of growth in the US, quite a bit of exports and a larger handful of imports. Factories are in the Midwest and South. They have never had a dedicated compliance person. Lots of stuff gets done on […]

  • Section 301, Assists and Transfer Pricing

    QUESTION: We ship US component parts to a related foreign supplier in China who in turn incorporates them into a finished product and exports back to us. I see an opportunity to lower our customs value and therefore avoid Section 301 duties but not sure how we claim the assist value on the item if […]

  • SEC. 301 EXCLUSION REQUEST

    QUESTION: With regard to the section 301 China tariffs exclusion form question 10, it asks you to provide the value for the previous 3 years. If the HTS code calls for “X” as the quantity, do you leave the quantity blank or would you provide some type of quantity such as how much you ordered […]

  • 301 entry pre-filing

    QUESTION: Looking to settle a debate: Can we pre-file entries using the 5 day parameter, selecting an entry date prior to 9/24 to avoid paying the additional 10% duty?   Or would AMS reject the entry when the vessel arrives 9/24 or later and force the additional duty due? ========== Answers: You can file and get […]

  • SEC. 301 DUTIES AND DFARS [S]

    QUESTION: I’m trying to confirm whether imported goods from China which would normally be exempt from duty under DFARS are now subject to the 25% tariff. My presumption is the normal duty rate is still exempt, but the 25% now applies. Can anyone confirm that?  I’ve not been able to find a specific statement addressing […]

  • Section 301 Duty Reimbursement [S]

    QUESTION: A question was asked recently as to if foreign producers can reimburse Section 301 duties paid by US importers.  Half the responses answered “yes” and the other half answered “no”. Can anyone provide the citation to support the correct answer? %%%%%%%%%% Addl ANSWERS: Legally you can be reimbursed.  It is not the same as […]

  • Section 232/301 Enforcement

    QUESTION: With increased enforcement on Section 232 and 301 expected, I heard there may be increased level of penalties for non-compliance with Section 232 and 301.  I heard during the 232 webinar from CBP, the increased penalties could be as high as 3X the value of the goods. Can anyone provide additional references, support or […]

  • SEC. 301 BOND INCREASE

    QUESTION: With the recent passing of the 3rd Section 301 list, our company will be affected and our import duty will increase. To assess the correct import bond amount, should we wait a year to have a full year’s worth of data with increased duties paid or should we do a projection now and increase […]