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APHIS – LACEY ACT PHASE VI – October 1, 2021

The following article submission has been provided by the NCBFAA (The National Customs Brokers and Forwarders of America): On Oct. 1, customs brokers will see new tariff flags for USDA’s Animal and Plant Health Inspection Service (APHIS) Lacey, requiring transmission of a Lacey Act declaration or a valid disclaim for products classified in these tariff categories. The product categories include new wooden pallets, containers or packaging that are NOT under load, some essential oils, additional musical instruments, oriented strand board, bi-pods and tripods, and trunks, cases, and suitcases. The specific HTS numbers are listed below. NCBFAA Regulatory Agencies Committee (RAC) Chair Mike Lahar of A.N. Deringer participated last week in a timely and informative webinar sponsored by the National Wooden Pallet and Container Association (NWPCA) on the APHIS Lacey requirements. He was joined by Karen Williams, Compliance Specialist at APHIS. The focus of the webinar was on pallets and both speakers emphasized that the declaration requirement does not apply to pallets (new or used) that are “under load.” Nor does it apply to used, recycled, or repaired pallets – whether empty or under load. In both cases, a disclaim code A or B must be transmitted. The declaration must be provided for new pallets that are the product being imported. Lahar provided a practical perspective on the filing requirements, clarifying when a broker needs to file the declaration, and when to transmit... Read More

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Goods Returning to the USA (update via Customs Message) 49132200

For years we have posted to our website publications of the changes taking place with “Goods Returning to the USA”.   At this time we want to inform everyone of the recent CBP message posting # 49132200.  Please read on.  This notification by Customs most likely will be very important to you, and essential in your understanding of CBP’s regulatory position on “returning goods” U.S. manufactured or foreign made, back to the United States of America.  Specifically in, defining your regulatory responsibilities as the IOR. importer of record (resident or non-resident). CSMS #49132200 – Updated Requirements for Importers and Brokers Regarding HTS Subheading 9801.00.10- U.S and Foreign Goods Returned This message provides updated guidance concerning (a) importer and broker responsibilities in filing duty free claims under Harmonized Tariff Schedule of the United States (HTSUS) Subheading 9801.00.10, and (b) documents that CBP may request to support claims under Subheading 9801.00.10. This CSMS message supersedes guidance CBP previously issued via CSMS 17-000046 on January 30, 2017. Background On April 25, 2016, a change to HTSUS Chapter 98 for U.S. goods returned went into effect. Specifically, section 904(b) of the Trade Facilitation and Trade Enforcement Act of 2015 (TFTEA), “Modification of Provisions Relating to Returned Property,” amended HTSUS Subheading 9801.00.10 to read as follows: Products of the United States when returned after... Read More

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CONSUMER PRODUCT SAFETY COMMISSION – 1USG

This article has been provided the National Customs Brokers and Forwarders Association of America (NCBFAA) for your information: CPSC Webinar Provides Insight on Managing the 1USG Messaging in ACE Consumer Product Safety Commission (CPSC) officials joined with customs brokers in a stimulating and informative webinar on CPSC’s 1USG Messaging at Import on June 18. CPSC panelists Deputy Director Sabrina Keller and International Trade Specialist John Blachere explained and clarified key elements of their newly implemented messaging system.  Customs broker, Adam Lees of Geodis, who has experience with the messaging system since the original pilot was launched over a year ago, shared useful pointers and best practice tips. Mike Lahar of AN Deringer and chairman of the Regulatory Agencies Committee (RAC) kept the conversation moving as moderator, highlighting areas of confusion and concern. John Blachere explained that whenever a broker files an entry for a product in one of 320 targeted HTS categories of CPSC-regulated products, the broker will receive an “Under Review” message in ACE from the CPSC. This message does not mean the product is being held or subject to physical exam, it simply signifies that CPSC is looking at the entry documentation. Following the Under Review message, a broker will in most cases receive a “May Proceed” message. Less common, the broker may receive a “Hold Intact” or “Intensive Exam Requested.” Blachere... Read More

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SECTION 301 – Additional China Duty Status

Arguments, Motions Scheduled for Section 301 Tariff Lawsuit Oral Argument Scheduled. On Thursday, June 17, the U.S. Court of International Trade (CIT) will hold an oral argument on plaintiffs’ motion for a preliminary injunction. The motion seeks to suspend the liquidation on entries involving the Section 301 duties challenged in the court cases. The government filed a memorandum opposing the motion and plaintiffs have asked to court to permit the filing of a reply to that opposition. The government stated it would defer to the court on whether to accept a reply. Because most court precedent supports the fact that an Office of the U.S. Trade Representative (USTR)-directed function, e.g., Section 301 tariffs, where Customs and Border Protection (CBP) performs a ministerial role, e.g., collecting but not deciding whether to collect duties, is not a protestable decision, many practitioners had advised that protests were unnecessary to preserve Section 301 claims.  However, recent activity in the case concerning the suspension of liquidation shows that even this threshold issue is not an entirely settled one. Motion for Judgment or Dismissal Filed. On June 1, 2021, the government filed motions to dismiss and alternatively for judgment on the agency Record. The deadline for the response is Aug. 2 and the Section 301 Steering Committee is actively and collaboratively preparing that response. Much of the government’s argument claimed that based upon its discretionary authority,... Read More

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FSVP – DUNS NUMBER (“UNK” TO TERMINATE JULY 2022)

UPDATE  (JUNE 14TH, 2021) No More ‘UNK’ for FDA Entries in July 2022 The Food and Drug Administration (FDA) told NCBFAA Regulatory Affairs Committee (RAC) members that use of the term “UNK” (representing “unknown”) will not be allowed for food imports in place of a valid DUNS number for in the Unique Facility Identifier field for the FSVP importer, starting July 2022. The agency has already started targeted outreach by sending emails to customs brokers and importers who have used UNK. Use of the UNK was officially allowed as a temporary measure in 2017 when the FSVP requirements were first implemented to give importers time to adjust to the new requirements. The process for obtaining a DUNS number can be lengthy. Customs brokers are encouraged to urge their clients to apply for a DUNS number now through the D & B Website line following: https://www.dnb.com/duns-number.html?utm_medium=email&utm_source=govdelivery The FDA is sending out notifications to advise the importing public who deal with food importations, that the “UNK” option (versus the actual report of a consignee’s DUNS number) is going to soon expire and importers will be required (in the near future) to supply their consignee / importers actual DUNS number within the entry record that your broker uses when transmitting your FDA data to Customs and to the Food & Drug Administration.   Please make sure that you work to obtain your DUNS number, or the... Read More

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VOIDED IMPORTER OF RECORD TAX (EIN) NUMBER – WHAT TO DO

CBP, since 2019 has taken to VOIDING Importer or Record tax (EIN – Employer Identification Numbers) numbers that are infrequently used on import entries.  This means that if you are an infrequent importer (once every 2 years or more) you will probably at some point in time have CBP VOID your tax number in their computer system (ACE).  Their void does not remove your number from the Internal Revenue Service records, only from the records of CBP (Customs & Border Protection Services). Previously CBP only VOIDED numbers for the the following reasons (listed below), but have recently taken it upon themselves to just VOID numbers that are NOT used very often.  Here is the link for the instructions on VOIDED Importer of Record numbers (their FAQ page) – https://www.cbp.gov/trade/priority-issues/revenue/bonds/voided-importer-record-faqs Commonly CBP reports that they VOID Numbers for these reasons: Importer records may be voided for the following reasons: Duplicate records are on file with CBP The importer’s Social Security number or Employer Identification number cannot be verified with the appropriate government agency (Social Security Administration or Internal Revenue Service respectively) The importer, their authorized agent (with a valid Power-of-Attorney), or local CBP Officer has requested that the record be voided CBP has received returned (undeliverable) mail when attempting to contact the importer via the US Postal Service Failure to respond to CBP requests... Read More

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Security

Welcome – Security

Security at Sanders Brokerage: Welcome, and we hope you enjoy the staff and services of Sanders Brokerage Services.  Hopefully by now you know a bit about the background and heritage of Sanders Brokerage Services.  We take security personally and hold our government’s security programs with high regard.  We have been a proud C-TPAT (Customs Trade […]

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USDA

APHIS – LACEY ACT PHASE VI – October 1, 2021

The following article submission has been provided by the NCBFAA (The National Customs Brokers and Forwarders of America): On Oct. 1, customs brokers will see new tariff flags for USDA’s Animal and Plant Health Inspection Service (APHIS) Lacey, requiring transmission of a Lacey Act declaration or a valid disclaim for products classified in these tariff […]

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FDA

FSVP – DUNS NUMBER (“UNK” TO TERMINATE JULY 2022)

UPDATE  (JUNE 14TH, 2021) No More ‘UNK’ for FDA Entries in July 2022 The Food and Drug Administration (FDA) told NCBFAA Regulatory Affairs Committee (RAC) members that use of the term “UNK” (representing “unknown”) will not be allowed for food imports in place of a valid DUNS number for in the Unique Facility Identifier field […]

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CBP

APHIS – LACEY ACT PHASE VI – October 1, 2021

The following article submission has been provided by the NCBFAA (The National Customs Brokers and Forwarders of America): On Oct. 1, customs brokers will see new tariff flags for USDA’s Animal and Plant Health Inspection Service (APHIS) Lacey, requiring transmission of a Lacey Act declaration or a valid disclaim for products classified in these tariff […]