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Ch.. Ch.. Ch.. Changes - To the Explanatory Notes

Posted by The Tradewin Team

6/20/14 2:49 PM

12When was the last time you made an appointment with your doctor for a check-up? If you are anything like me, it’s been awhile. In fact, as I’ve set out to write this blog I’ve realized I haven’t had a physical in probably close to a decade. But, what really could have changed in just 10 years? Has my body changed that much?

Truth is, there is probably a lot that has changed, and with the health risks that run in my family such as heart disease, this really isn’t something I should let slip.

I could make a dozen excuses, my favorite of which is saying “Life gets in the way”. I mean, life happens, right? We always set out with the best of intentions, we make plans, and for a time even follow through with them, but inevitably, something (Life) gets in the way. When I bought my now 5 year old truck, I swore up and down that I would not only keep up the maintenance on it, but even fill out the record log in the back of the owner’s manual. Well, as I am sure you can guess, 5 years and 60,000 miles later, the only thing still pristine about my truck is the owner’s manual. Don’t get me wrong, I still take it to get the oil changed when the light comes on, and even get the air filter changed when my mechanic yells at me. But those things have become habit, the normal ebb and flow of life. We fall into a groove or way of doing things and often forget to take the time to see if anything changes. We forget to do the maintenance.

Recently, the World Customs Organization met for its 53rd session. In this session, among other things, they discussed making amendments to the Explanatory Notes. For those of my readers who are unfamiliar with the Explanatory Notes, while not legally binding, they are the globally accepted interpretation of the Harmonized Commodity Description and Coding System (Tariff System) and are (or at least should be) used as a regular guidance for classification of items under the HTS. They assist with and give guidance to areas such as what is considered to be part of an aircraft under heading 8803 or what types of metals and stones are considered precious or semi-precious, and which are not. While the section and chapter notes do a good job of helping one interpret what is and what is not included in given areas of the Tariff, the Explanatory Notes will often times go further in depth and include examples.  In this particular session, the WCO made amendments to 15 parts of the Explanatory Notes. Albeit, the amendments all seem to be to heading 3002 and earlier, but this is still worth taking note of. Just as CBP regularly issues changes to the Harmonized Tariff Schedule of the United States, the WCO issues amendments to the Explanatory Notes. Often times, just as in car maintenance and our general healthcare, “Life gets in the way” and we forget to stop and review what we think we already know.

When I find myself thinking I already know something, often times I find that thing has changed.

Is it necessary to go back every time you classify an item and check all your resource materials again? Should you go back and review your parts database (see my last blog on this one!)? Should you subscribe to news feeds or blogs for updates on changes such as the amendments to the Explanatory Notes? Where do you start?!?

Well, as my Grandpa Cousino said, “If you don’t know where to start, go back to the beginning.” Or at the very least, subscribe to this blog and stay in the loop.

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Topics: Classification

Written by The Tradewin Team

Since 1997, Tradewin has been providing expert import and export advice to clients all over the world. Combined, our skilled team of Customs brokers, lawyers, accountants and other professionals possess more than 400 years of experience. Together, we've helped thousands of clients save more than $50 million in duties, guiding them through the ever-changing and complex arena of international regulations as effortlessly as possible.