DISCLAIMER: This is not intended to be a rant on CBP. I respect the office and institution, however, speaking as an importer of a wide variety of commodities I strongly feel that there is a need to shed a spotlight on very real opportunities that would be considered mutually beneficial.
Top Areas In Need of New/Updated Informed Compliance Publications
- Ceramics (namely, available in specified sets) - I cannot tell you how many calls, Customs inquiries and rejected PSAs I’ve received regarding ceramic dinnerware and other tableware. I have certainly done my due diligence, called (and talked to) the NIS, kept detailed notes and, when exercising the “available in specified sets” provision make sure the vendor provides an affidavit supporting the availability of the set pieces, a item and price list and copies of their catalog pages and/or website catalog. STILL, I get the calls. I was even asked to bring a sample by an unnamed Port office and had to explain what “available in specified sets” really meant because the particular import specialist I was talking to was “a bit unclear.” An ICP for ceramics would not only keep those of us in the trade informed and knowledgable but would help educate Customs’ own field people.
- Wood Products (and all of Chapter 44) – Sources inside Customs even say this Chapter is a mess. My previous post in regard to the bamboo exclusion except for flooring still throws me. The growing number of “sustainable” items being manufactured out of bamboo and other sustainable wood sources is going to crush the poor wood team at Customs because it is not intuitive to classify solid hard wood bamboo vases (for instance) as baskets under Chapter 46. Just does not make sense.
- Valves (and the whole 8481 subheading) - When a ceramic beverage jar is ruled as a valve but a glass beverage jar is ruled as an article of glass there is a real disconnect somewhere in Customsland. As an importer, I feel set up to fail. An ICP specific to this area would help the importer but would indirectly force Customs to get on the same page across all commodities – or at least one would hope.
- Ribbon (and like trimmings) - I don’t even know where to start. There are so many possible areas for classifying ribbon it gets hard to keep track of (and train to!)
- Festive - A REAL guide to help the importer understand what is/is not festive would be incredibly helpful!
More to come! Fortunate for me there is no shortage of material to work with! Stay tuned for additions to the list!
Filed under: Classification | Tagged: bamboo, CBP, ceramics, festive, Informed Compliance, ribbon, valves, wood
