6165 Barfield Road
Atlanta GA, 30328
United States
Tel: +1 (770)688-1206
Fax: +1 (770)688-1229
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!
For December, we are highlighting Jeffrey Bispham on the West Coast! Jeff has been in the industry for 26 years and remembers using a typewriter to prepare 7512's. He has always worked in the import/customs brokerage side of logistics. Jeff was adopted as part of the JAS Family when JAS acquired Tigers back in 2021 where Jeff had long tenure.
In October 2023, the JAS Forwarding (USA) Tacoma Foreign Trade Zone became an active FTZ in the JAS USA Network. Jeff became the FTZ administrator of that site and has been instrumental in building the compliance for our FTZ site on the West Coast.
Jeff enjoys all sports, although he would tell all that he has become more of a spectator than a player as the years have passed. Jeff enjoys being outdoors. But most of all, he enjoys spending time with his family. That time can often occur at the beach, or a Seattle sporting event (Mariners, Seahawks and Kraken).
Jeff is yet another great example that People Make the Difference!
In November, JAS USA Corporate Compliance team members teamed up with JAS Atlanta Branch team members to facilitate client compliance training. From left to right, Calvin Oh (Corporate Compliance), Scott Cassell (Corporate Compliance), Carlo Rebuffi (Manager of Live Animals Division-ATL), Laurie Arnold (VP Corporate Compliance), and Rishma Patel (CHB Manager-ATL). The team was able to facilitate learning on the topic of import compliance.
OFAC (Office of Foreign Assets Control), part of the Department of Treasury, has imposed a $1.1 Million penalty on a US individual. The panlty was issued for 75 violations of OFAC Iran sanctions.
To read the full details check out the link below:
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