QUESTION: Can non-direct labor cost (such as overhead) be counted as originating for purposes of RVC? ===================== ANSWERS: To answer this question read the portion of the General Notes in the HTSUS that applies to the specific free trade agreement which allows for RVC — that specifies what costs can be used. ===================== If using […]
QUESTION: The final product is 8537.10 It has parts classified in 8538.90 valued over de minimis The tariff shift rule is: A change to headings 8537 through 8538 from any other heading. The rule does not mention if the change of headings from any other heading includes within the headings of 8537-8538 or […]
QUESTION: I found a pad of US Israel Certificates of Origin with a copyright of 1985. The only difference I can see between that and the 1993 version is box 11 – the older ones are missing the “Exporter as producer” portion of the box. Can I still use them or will they cause issues […]
QUESTION: Has anyone in the membership been asked to backdate the “date signed” block on FTA certificates? I have been receiving these requests for certificates for Peru and my response is always no. Some customers want the certificates to be dated on 1/1 of the current year, but I am refusing to backdate the date […]
QUESTION: I am in a new job and have noticed that the company provides a lot of generic certificates of origin with their shipments. Generally there is one certificate for each shipment regardless of any blanket period listed on the sheet. I will stress that at this time, we are NOT providing any NAFTA certificates […]
QUESTION: Does a supplier in South Africa need to apply to export under AGOA benefits? If so, how does the application process work? If an approved AGOA exporter in South Africa purchases parts from a non approved AGOA exporter and then exports the parts to the US, is it possible for the US importer to […]
QUESTION: I want to know according to the non compliance ruling if I have fabric from Korea that is cut in USA and sent as cut parts into a CAFTA country to be sewn and exported into USA Is this still compliance or not ? The fact that has been cut in USA made it […]
QUESTION: Can someone in the handbag industry or anyone following GSP advise a timeline for the travel goods and handbags added to GSP? Originally they were estimating a July 1, 2016 implementation. Is this still on schedule? Anyone expecting any pushback that delays implementation? ======================== ANSWER: You might want to check with the American Apparel […]
Question: I am trying to find English versions of the text for Free Trade Agreements between Brazil and other South American countries. I want to determine the rules of origin, the countries involved, the duty rate if not free and any possible taxes that might be incurred shipping from Brazil. Would anyone in the membership […]
Question: We are asking our Korean supplier to provide evidence of compliance with the US-Korea FTA. According to CBP’s verification requirements, the Importer is responsible for substantiating the validity of a preference claim. 1- Can the membership advise, has any company been able to obtain such supporting documents from their Korean supplier? Has the membership […]
Question: If the amount of just labor and overhead for the production of a US finished article (made from both US and imported parts) is greater than 35% (build up method), would a good be considered as qualifying for the US Chile FTA? Can labor and overhead be considered in the equation as value of […]
Question: Does anyone in the Membership have experience with usage of the US/Israel FTA? We’re looking for advice relating specifically to that FTA. Anything we need to watch for, any pitfalls or peculiarities unique to that FTA? **************** Answers: Read the instructions carefully, it is clearly a valuation qualification approach. You will need cost accounting […]
