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2.5% or free of duty? It can represent a large sum if the value is high and or the volume of entries is strong. But picking harmonized tariff codes based on duty rates is not only incorrect, it is against the laws that govern trade. The HTSUS (harmonized tariff schedule of the United States) is not a guide, it is a legal document backed with “teeth.” Failing to effectively classify commodities can lead to CF28’s (requests for information), CF29’s (notices of action often increasing the duty liabilities to the importer), focused assessments and audits. All of these are efficiency killers in today’s modern fast paced supply chain environment.
CF28’s take time and resources to provide appropriate answers to CBP. CF29’s take time and resources to review, rebut and sometimes to apply subsequent payments to an entry that may already be completed and closed in the books. Focused assessments and audits are a whole new level of resource taxing for an importer compared to CF28’s and 29’s.
So what can importers do?
First of all, importers should begin classifying according to the General Rules of Interpretation codified in the HTSUS. These rules provide the framework to follow a process to obtain correct HTS codes.
Second, importers should assess they database of commodities and determine items which need to be re-assessed.
Finally, an assessment of CF28’s and CF29’s should be examined. How many have been received in the past 12 months? How many have been answered? What items were affected by the requests? Have those items been updated inside the internal databases of the importer?
JAS Forwarding USA Inc. Compliance Team is experienced in all of these questions. We have solved these problems and can help. Contact us today and we will assist to analyze risk in this arena as well as others!
A multinational organization based in Bangkok, Thailand, has agreed to pay $20,000,000 to settle potential civil liability for 467 apparent violations of OFAC sanctions on Iran. Between 2017 and 2018, the company facilitated $291 million in wire transfers through U.S. financial institutions for the sale of Iranian-origin high-density polyethylene resin (HDPE), manufactured by a joint venture involving the parent company in Iran. HDPE is a robust resin used in various plastic products such as food and beverage containers, shampoo bottles, and industrial items. Concurrently, the company initiated U.S. dollar wire transfer transactions to settle the joint venture’s debts to third-party vendors.
BIS has released the newest iteration of their guidance on export enforcement. The “Don’t Let This Happen to You” guidance document is dated March 2024 and is 76 pages of important guidance for the export community. The opening letter states “Export controls have never been more important to our collective security interests than they are today.” Follow the link below to check out more details!
The U.S. Customs and Border Protection (CBP) has issued a Withhold Release Order (WRO) against work gloves manufactured in a Chinese company and its subsidiaries, based on evidence suggesting the use of convict labor. This action is part of the U.S. government's efforts to combat forced labor globally. With nearly 28 million workers suffering under such conditions worldwide, WROs are a means to deter companies from exploiting labor and to protect vulnerable populations. By enforcing laws prohibiting the importation of goods produced by forced labor, CBP aims to safeguard American workers, businesses, and consumers. Currently overseeing and enforcing numerous WROs and Findings, CBP emphasizes its commitment to eliminating forced labor from U.S. supply chains and encourages reporting of suspected violations.
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