WELCOME TO IMPORTING 101 Are you ready to make a compliant international import transaction?
IMPORT REGULATIONS Responsibility for compliance . Acting through a customs broker does not relieve anyone of the responsibility for compliance with CBP. Forwarding agents, carriers and others who participate in these transactions are also responsible for complying with CBP.
HS NUMBER CLASSIFICATIONS You can search your product on the below website. http://www.usitc.gov/tata/hts/bychapter/index.htm Having the HTS number of your product(s) on your commercial invoice and/or packing list is always best. CROSS – Customs Rulings Online Search System Proper classification of your imports and outsourced OEM (Original Equipment Manufactured) productions as you add them to your product line. Knowing the proper classification is critical in determining the landed costs of your product. This service allows you to look up and determine previous rulings on your product or similar products. http://rulings.cbp.gov/
HS NUMBER CLASSIFICATIONS CONT’D E- Rulings can be applied for allowing an importer to ‘lock in’ an HTS for their specific product(s). Requirements: All technical, diagrams and descriptive material as it pertains to the product to be ruled upon. Intended HTS to apply for (work with and through your current customs broker).
KNOW YOUR SUPPLIERS AND KNOW THE SCOPE OF YOUR PRODUCT FROM THEM Choosing a Foreign Supplier from a Customs Perspective Know your supplier, use the following websites for reference, Entity List, Denials List, Debarred list, Unverified list, Sanctioned, anti- boycott compliance, common red flags. www.ustreas.gov/ofac, www.bis.doc.gov, www.trade.gov/td/tic/ Know your commodity, what additional duties may apply to your imports. The following link provides updates countries of origins and those products from them penalized through additional duties (ADA/CVD). Scope information by country of origin http://web.ita.doc.gov/ia/CaseM.nsf/136bb350f9b3efba852570d9004 ce782?OpenView&Start=1&Count=30&Expand=21#21
ISF FILING 10+2: Anti-Terrorism Security Reporting 12 additional data elements now required to be filed 24 hrs prior to a shipment’s lading on the vessel bringing the goods to the USA. ISF Rules and Potential fines While no fines have yet been levied, CBP reserves the right to fine an importer up to $5000.00 per violation up to 6 years from the date of the original violation. What information is needed from the Importer to file ISF? Seller, Buyer, Importer, Consignee, Ship To, HTS, Manufacturer, Country of Origin… Failure to file an ISF or timely ISF can result in exams and delays at the first port of arrival and at the port of entry in the US. All of which creates additional costs (monetary and time) for the importer.
EXAMS Why is my freight always getting stopped and examined? A known problem supplier into the US. Suspicious country of origin. Failure to comply with ISF, FDA or other import regulations timely and accurately. Highly scrutinized import product. Previous incorrectly classified imports into the US. Previous wood packaging issues or mislabeled products into the US.
CONTINUOUS BONDS AND THEIR BENEFITS Ability to file a paperless entry in any valid US port of entry. Quicker electronic releases – no need to file paper declarations. Allows for one centralized broker to file entries for an Importer nationwide. Importers without a CTB are allowed only a certain amount of ISF filings per calendar year. Cost Savings Entries not under CTBs must be cleared using an STB (Single Transaction Bond) carrying a minimum cost of $50.00 per entry or $5.00/$1000.00 of invoice value plus duties. ISF STBs also required. Entries containing OGAs (Other Government Agency filings) are then valued at 3x the invoice plus duty values.
OTHER GOVERNMENT AGENCY (OGA) FILINGS FDA (Food and Drug Administration) Food products, drugs, tableware, laser products Requires parallel filing with CBP. Prior Notice required on all human/animal food/food-related imports. DOT (Department of Transportation) Autos, tires, many motor vehicle accessories Fish and Wildlife Animal products, CITES protected products, live animals, etc… FCC (Federal Communications Commission) Computers and accessories, radio/data transmitting/receiving apparatus Lacey Act Certain wooden products EPA (Environmental Protection Agency) Engines, pesticides, fuels TSCA (Toxic Substance Control Act) products, chemicals, paints, etc… CPSC (Consumer Products Safety Commission) Toys, baby goods, car seats, etc…
DOCUMENT RETENTION You should always receive a complete entry packet with all rated invoices and packing lists, copies of any international bills of lading and copies of the import 7501 and 3461 from your broker. Document retention is required 5 years from the date of entry. Are there penalties if you do not retain them? Failure to maintain or produce records: Willful: not to exceed $100,000.00 per release or 75% of the appraised value, whichever is lower. Negligence: not to exceed $10,000.00 per release of 40% of the appraised value, whichever is lower. Electronic, paper, or offsite storage is acceptable.
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