• First Sale for export

    Question: Has anyone had experience with the First Sale for Export (FSE) rule?  What specific documents does the importer need to comply with this rule? As the importer, we issue the purchase order (PO) to the foreign vendor under EXW terms. This vendor acts as the middleman or owns the factory. Currently, the middleman provides […]

  • Export Value

    Question: Thanks to the membership in advance.   In 15 CFR 30.6(a)(17) Census requires adjustment to the selling price for inland or domestic freight, insurance, and other charges to the U.S. port.  I would appreciate if members would share some best practices for practical implementation of this requirement, such as: how you calculate; how and where […]

  • Discounts

    Question: What is everyone’s thoughts on claiming a discount?  I’ve worked for a couple different customs house brokers, and they all seem to have different thoughts on discounts the last one hour for really would not claim any sort of discount, so I really wanted to get everyone’s thoughts on claiming a discount. Asked by: […]

  • Discount on proforma invoices

    Question: Hello ICPA, I have the scenario related to discounts in valuation.  Shipper and IOR are related, but product is being sold to US third party directly. Some proforma invoices contain a customer discount (customer specific), discounted from the value of the merchandise. Example: Line item value $1,300, discount $ 180, total invoice value $ […]

  • Shower Enclosure

    Question: We import shower enclosures with glass panels, aluminum frame and a fiberglass shower pan.  This is imported as a complete shower kit, all of the parts to assemble included. Two questions for the group. There are two bonding rulings, N304708, Tariff number: 7610.90.0080 and N248690, tariff number 7013.99.2000, which one is the better tariff […]

  • Testing costs for imports

    Question: Do testing costs have to be included in the FOB value for imports?   We are looking to pay them separately, rather than include in the FOB cost, and are not sure if Customs would have an issue with this. Answer 1: It depends on to whom the the importer is paying the testing fee. […]

  • Reduced cost

    Question: Company A located in the US is offered a reduced price to purchase excess stock from a vendor in China. The reduced value will be 80% of what is typically paid.  If CBP were to question the valuation, what would be a reasonable explanation for the lower cost shown on the invoice?  In some […]

  • valuation confirmation

    Question: We recently received two requests from two different entities (one related and one not related) in two very different parts of the world to explain the value of sample material our entity is shipping into those countries.  I think these are coincidental requests and not related. The request from the unrelated entity was not […]

  • Additional Labor Costs

    Question: We are possibly asking some foreign supplier factories to work additional overtime above our standard labor rates. For this we would possibly give them additional compensation. However, as we do that we really have no way to say exactly what items, on what PO, or to what global region those costs should be added […]

  • Samples

    Question: I would like to ask the Membership what risk there is to understate a value of SAMPLE product not for sale, especially product that is being tested or in the innovation stage.  I work for a food company with manufacturing and sales in Europe and Mexico and I have given guidance to always use […]

  • Samples

    Question: I would like to ask the Membership what risk there is to understate a value of SAMPLE product not for sale, especially product that is being tested or in the innovation stage.  I work for a food company with manufacturing and sales in Europe and Mexico and I have given guidance to always use […]

  • Commercial Invoice Value on Arm’s Length Transaction

    Question: We have a customer in Mexico that purchases FCA-Laredo from my company in the US.   We need to send them some equipment that is leased, not sold to them.  The lease is $75, but the equipment is worth $5,000 USD.   Our commercial invoice shows the $75 lease value. Do we need to change the […]