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Are your classifications changing? Ask Alba.

Joe DeSilvestri

January 19, 2022

The Harmonized Tariff Schedule of the United States, or HTS, is the guiding document for customs brokers who classify imported merchandise. Published by the US International Trade Commission, this compendium which in its paper form is measured in pounds and inches thick contains all the information necessary to ascertain classification, duty rate, whether or not reduced or duty-free eligibility exists under a bilateral or multilateral trade program and rules of origin for regional value content for programs such as the USMCA.

The transition to a paperless entry and work environment hurried along by the pandemic means this thousands-of-pages-long document that covers satellites (8802.60.3000) to shrimp (0306.16.0040, but only if shell on and peeled in accordance with Statistical Note 1 of the chapter) and everything in between means importers have relied on other versions of the document that have been uploaded and integrated into Global Trade Management (GTM) platforms or word-searched PDF’s.

Regardless of what version you use, how wide or narrow your range of tariff numbers or even whether or not you use the HTS, CROSS rulings or rely on someone like Alba’s customs specialists to do the work on your behalf, these ten-digit numbers are shared with countries around the world until you get to the last handful of statistical suffixes.

Those statistical suffixes change frequently, and every five years, there are major changes to the HTS and later this month, the changes approved by a Presidential Proclamation at the end of December will come into effect. Many HTS numbers will not see a change, some which change will be revenue-neutral but some will lead to significant duty changes.

One such change we have seen would change the classification on a wearing apparel item from 6% to 32%. 

At a time when supply chains are beset by increases in first-line transportation costs, adding to the landed cost of an item with additional duty is unwelcome news.

Brenda Custer-Espeleta, Alba’s new EVP of Trade and Compliance, is focused on helping our customers react to this by evaluating the HTS for other viable classifications, weighing submission of a binding ruling request or exploring both legal means to reduce dutiable values or challenge the classification with CBP or in court.

To learn more about our customs compliance services, contact Alba today.