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Importer Security Filing

On January 26, 2010 You MUST File a 10+2 or Face Penalties!

U.S. Customs and Border Protection is serious. On January 26, 2010 they will start issuing penalties for failure to comply with the Importer Security Filing (ISF), also known as the 10+2. We can file for you or your shipper overseas can do it, but someone must. Failure to file will result in a $5,000 per violation penalty. You can also be fined for filing incomplete or wrong information. Therefore, the total penalty per shipment could be as much as $10,000.00.

Customs' regulations require that this information be filed 24 hours prior to the loading of the vessel. In order for us to accomplish this, we need to receive the documents 4 days before departure of the vessel. This will give us ample time to file and save you from facing a penalty. If there are any corrections we will need that information immediately so we can update the information with Customs. I cannot state enough that this is YOUR responsibility and YOUR penalty.

U.S. Customs is also requiring an additional bond for the ISF. This can be done with a single ISF bond, which will carry an additional charge. The shipment and ISF can also be bonded with a continuous transaction bond.

Arizona Customs Brokers is here to assist you with this filing and the bond. On our website, arizonacustomsbrokers.com, you can download "The Importer Security Filing Data Sheet", found under forms. We have setup a special email address for you or your overseas partner to send the form and documents. This address is isf@arizonacustomsbrokers.com. If you have any questions regarding the ISF or bonding requirements please give Robert Hornyan a call at 602-273-0912. We are here to assist you and keep you penalty free.

2020 Federal Holidays

Date Holiday
Wednesday, January 1 New Year's Day
Monday, January 20 Birthday of Martin Luther King, Jr.
Monday, February 17 Washington's Birthday
Monday, May 25 Memorial Day
Friday, July 3 Independence Day
Monday, September 7 Labor Day
Monday, October 12 Columbus Day
Wednesday, November 11 Veterans Day
Thursday, November 26 Thanksgiving Day
Friday, December 25 Christmas Day

If you have questions, please contact your assigned Client Representative.


New Tariffs on Steel and Aluminum Finished Products: What Can You Do?

Tuesday, January 28, 2020

Effective Feb. 8, the U.S. is extending its Section 232 additional tariffs on steel (25 percent) and aluminum products (10 percent) to specific finished products made with steel and aluminum. These include iron or steel nails, tacks, drawing pins, and staples- aluminum stranded wire, cables, and plaited bands- and steel or aluminum bumper stampings for motor vehicles and body stampings for agricultural tractors. Click here for more details.

With such a short time until the effective date, importers of affected products may wonder what options they have for avoiding or mitigating these tariffs.

One option may be to shift sourcing. Covered steel products from Argentina, Australia, Brazil, Canada, Mexico, and South Korea, and covered aluminum articles from Argentina, Australia, Canada, and Mexico, will be exempted from the additional tariffs altogether.

In addition, a process for requesting exclusions from the tariffs for specific products is expected to be developed in the near future. Exclusions may be granted for derivative articles determined not to be produced in the U.S. in a sufficient and reasonably available amount or of a satisfactory quality, or based on specific national security considerations.


Determining Origin for Section 301 Tariffs Poses Challenges

Thursday, September 05, 2019

Sandler, Travis and Rosenberg Trade Report

There continue to be conflicting reports in the press about the correct test to apply to determine country of origin for purposes of the Section 301 tariffs the U.S. is currently imposing on imports from China. Importers should be aware that while the COO claims made by their vendors may be correct under the source country's rules, they may be incorrect under U.S. rules. With an ever-increasing tariff burden at stake, as well as potential penalties for getting it wrong, it is important for importers to understand the applicable rules and verify COO claims made by their suppliers.

Unlike rules for value and classification, COO rules are not harmonized internationally. Countries often develop their own COO tests or adopt one from a particular free trade agreement. Even within a country the tests can vary depending on the specific issue involved. For example, different origin rules can exist for FTAs, product marking, or preference program qualification, to name a few.

The U.S. uses various COO tests in various circumstances, and there are essentially two tests used for determining COO for purposes of Section 301 duties: (1) substantial transformation or (2) the special origin rules found under 19 CFR Part 102. Which one to use depends on the product at issue.

As a result, COO tests used by the country of manufacture (e.g., a specified percentage of local content) may not be applicable to determining origin for U.S. import purposes. Similarly, the last country of processing and export may not be the country of origin for U.S. purposes.


TSCA Title VI Import Certification Begins March 22

On March 22, the TSCA Title VI import certification requirement that applies to composite wood products (panels of hardwood plywood, particleboard, medium density fiberboard, thin-medium density fiberboard, etc.,) component parts containing such composite wood products, and finished goods containing such composite wood products that are imported into the U.S. goes into effect.

The EPA has updated its "Tips for Trade when filing an EPA TSCA Certification in ACE" as guidance for the Trade when filing certifications. In addition to certification, under the TSCA Title VI regulation, importers must also:

•Keep Records. Take reasonable precautions by retaining, for three years, bills of lading, invoices, or comparable documents that include a written statement from the supplier that the composite wood products (or component parts/finished goods) are TSCA Title VI compliant.
•Provide Records on Request. When EPA requests, make available within 30 days records identifying 1) the panel producer and the date the composite wood products were produced- and 2) records identifying the supplier, if different, and the date the composite wood products (or component parts/finished goods) were purchased.


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