TradeLane

China has been included in the Canadian General Preferential Tariff (GPT) treatment since its inception in 1974. GPT was put in place to allow Canadian importers access to products from developing countries at a reduced duty rate to help stimulate the developing country’s economy. Wow!! I would say it worked for China.

A little history lesson. Back in 1974 we were entertained by best picture Oscar winner The Sting. “The Way We Were” was the number one song on the top 100. “The Streak” was number eight. The what? Don’t ask. The best-selling North American car was the Ford Pinto leading the way with explosive sales. China’s Gross Domestic Product (GDP) was about 45 billion.

How long has the reconciliation program been around? The prototype – yes prototype – will celebrate its’ 16^th birthday this coming October 1^st. So imagine my surprise when I was recently contacted by an importer that had been “kicked out” of the program. Since that phone call several months ago I have been made aware of no less than five importers that have either received the “boot” or been “put on notice.”

Historically Customs and Border Protection (CBP) has put up with importers that are habitually late with their reconciliation filings. Meaning CBP – via FP&F – issues the NO FILE liqudated damages notices, the importer has their filer process and file a reconciliation entry, CBP mitigates the penalty, the importer pays the Option 1 amount, and we repeat the process again next month. Works for everyone involved right? CBP gets a little more money via the Option 1 amount, the importer doesn’t have to increase headcount or reallocate resources, and the recon filer gets more filings this way. These habitually late importers – and they know who they are – seem to have taken the stance that they would rather pay $500.00 each month for late files rather than address the problem.

I’m often asked for a link to one government site or another.  There are certainly hundreds of sites to choose from. Sometimes you can’t see the forest for the trees.  Here is a short list of web sites that contain some basic guidance for a laundry list of compliance issues. 

Have a favorite of your own that didn't make the list? Let us know in the comments below. 

Over the last two weeks, requests for training seminars and workshops have really accelerated.  It might be our charming speakers, the nice weather, or perhaps, unbeknownst to me of course, that they are serving sangria at lunch. Regardless of the reason I thought I would touch on some of the unsung benefits of HTS Classification training. 

If you are in compliance, at some point in your career you have asked an engineer for the type of screw in a machine. Maybe you asked what it was made out of, or the head type, and they looked at you quizzically and likely ignored your request. They may have given you the look that said… “Those regulatory people must be fun at parties...”  (We are, but only because the Tariff drives us to drink).  For those lucky people with apparel classification, we need to know the thread count… really we do.

As a part of U.S. Customs and Border Protection’s (CBP) commitment to educate the Trade Community, Informed Compliance Publications (ICP’s) provide guidance around complex import regulations. On July 9^th 2014, CBP issued a draft revision to the ICP entitled “Bona Fide Sales & Sales for Exportation to the United States”. This ICP is key in outlining the requirements to appraise imported merchandise using the First Sale for Export value. In this early draft, CBP is proposing significant changes to this 2005 publication.

It is important to understand how these changes may influence an importer’s First Sale for Export program structure and is a great opportunity to evaluate its risks and rewards. Please remember that the ICP update is draft of the proposed language at this date. Some of those proposed changes highlight and reiterate the following: