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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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FORECED LABOR – IMPORTER BEWARE

FORCED LABOR: We ask you to take immediate notice of a situation certainly not new, known as “FORCED LABOR”.  CBP – U.S. CONGRESS and other NON-GOVERNMENT stakeholders are pushing hard trying to stop the proliferation of the utilization of FORCED LABOR throughout the globe.  What has brought this to the forefront is the findings in the Xinjiang region of China where situations have found that FORCED LABOR is being used in the production and harvesting of Cotton.  The basic legal provision that outlaws FORCED LABOR is 19USC 1307, where it states that “All goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in any foreign country by convict labor and/or forced labor and/or indentured labor under penal sanctions shall not be entitled to entry at any ports of the USA and importations thereof is hereby prohibited…”  The remainder of this notice is short but part of what we want to pass along or advise you of is, that importations of Stevia have been detained and seized by the U.S. Government, with penalty notices issued to the U.S. Importer.  Further it has been reported at the port of Blaine, Washington that containers of clothing were refused entry by CBP  because it was believed by CBP Officers that the clothing articles were made in whole or in part of Cotton manufactured with forced labor.  No proof of any such claim by CBP was necessary in making the CBP their assertion and in the end CBP invoked refusal of the shipments. ... Read More

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Section 301 China Exclusions – Cautionary Warning

As most will recall, the U.S.A., has been involved in a very large trade war with China under the Section 301 provisions of our regulations, amounting in additional Tariffs, from 7.5% up to and including 25% (additional duty’s).  A large number of “EXCLUSIONS” were issued throughout the years, some as resent as September of 2020 reduced these additional duties.  We caution all importers and ask that you be aware that many, and most likely all, of those exclusions (which granted lower or no additional duties) are set to expire on December 31, 2020.  Should these exclusions expire on December 31, 2020 it is our conjecture that the Section 301 duties could revert back to 25%.  Again, this is only our opinion, but returning to 25% additional duties is exactly what happened in August of 2020 when certain other exclusions expired.  The United States Trade Representatives (USTR) in September reinstated those exclusions through December 31, 2020 making them retroactive to August 7th, 2020, however, importers (through their broker) had to request Post Summary Corrections (PSC) or protest entries refund duty money’s paid in excess.   It will be very hard to predict what the United States Trade Representatives will be instructed to do in the remaining months of the current Presidents Administrative authority.  Additionally, there is no way to know, read or guestimate as to what the President Elects’ opinion will be on the Section 301 China tariffs... Read More

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PREPARING FOR THE 2020 BIENNIAL REGISTRATION RENEWAL

The announcement below is for our FDA clients who have an FDA Registration Number.   Preparing for the 2020 Biennial Registration Renewal In preparation for the 2020 Biennial Registration Renewal period, we have a few tips: Ensure that your FURLS account is up to date with a valid password Please visit https://www.access.fda.gov/ to access your account. If you have forgotten your Account ID and/or password, please select ‘Forgot Account ID’ and/or ‘Forgot Password’ to obtain your login information. If you have not accessed your account in over 90 days, you will be required to create a new password. Please visit https://www.fda.gov/food/online-registration-food-facilities/fda-industry-systems-account-management-guide for more information on managing your account or resetting your password. If you require further assistance, please call our FURLS Helpdesk at 1-800-216-7331 or 240-247-8804 or email FURLS@fda.gov. Due to the high call and email volume received during the renewal period, we encourage you to contact us in advance of the renewal period for account management assistance.   Obtain or verify your facility unique facility identifier (UFI) In accordance with 21 CFR 1.232(a)(2), beginning October 1, 2020, the facility’s UFI recognized as acceptable by FDA will be required to be submitted with the registration information. At this time, FDA recognizes the Data Universal Numbering System D-U-N-S (DUNS) number as an acceptable UFI. DUNS numbers are assigned... 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

Wood Packing Material

THE U.S.D.A., SAY, Make sure your wood packing material has been properly heat or methyl bromide treated!   U.S.D.A. is refusing shipments that contain pallets and wood packing material that is not properly marked are treated with ISPM 15 or IPPC logos.  Make sure your shipment is admissible and become familiar with the information on the […]

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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

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 […]