As we approach the new year, importers need to gear up for a successful and compliant 2024. Staying on top of regulatory changes and ensuring adherence to customs requirements is crucial.
Compliance Check Focus Items
Blanket ADD Non-Reimbursement Statements
Importers should meticulously review and update their Blanket Anti-Dumping (ADD) Non-Reimbursement Statements to encompass the annual 2024 period. This step is vital to ensure your company remains compliant with ADD regulations.
Blanket Certificates of Origin
A thorough review and update of any Blanket Certificates of Origin for any Free Trade Agreements covering the annual 2024 period. Keeping these certificates current is crucial for compliance with origin requirements especially when declaring reduced duty treatment under a preferential or free trade agreement.
Quota Preparation
Collaboration with customs brokers is crucial for importers dealing with commodities like Beef, Tuna, and others subject to annual quotas. Be proactive in preparing documentation for withdrawal from bonded warehouses or filing customs declarations as the quota period opens on Jan 02, 2024 as these quotas (Beef and Tuna) often fill upon opening.
HTS Evaluation
Given that HTS codes often change at year-end, importers should stay vigilant for any updates effective from Jan 01, 2024. While the exact changes might not be available before Dec 18, 2023, awareness is key to compliance.
Expiration of Sec 301 Exclusions
Prepare for the end of any Section 301 China Exclusions. Unless there are last-minute announcements by the US Trade Representative, Commerce, and the President, shipments previously eligible for exclusions will now be subject to Sec 301 duties.
Triennial Report
Importers with licensed customs brokers (LCB) on staff must ensure that their LCB files the Triennial Status Report by Feb 29, 2024.
Additional Information to Stay Compliant
Implementing Customs Compliance Best Practices
Determine the Scope of Imports
Use Automated Commercial Environment (ACE) reports to identify all goods for which your organization and its affiliates act as the importer of record.
Evaluate High-Risk Imports
Identify and scrutinize imports likely to face CBP scrutiny, including those from China, goods with potential antidumping or countervailing duties, and those relying on preferential tariff measures.
Conduct a Classification and Valuation Review
Regularly review and confirm the accuracy of HTS classifications and valuation methodologies.
Conduct an Antidumping and Countervailing Duties Product Review
Ensure compliance with AD/CVD tariffs and prevent circumvention of existing orders.
Confirm Proper Payment of Section 232 and Section 301 Duties
Carefully review aluminum, steel, and Chinese imports to ensure proper recording and payment of associated tariffs.
Evaluate FTA Claims
Review and confirm the accuracy of Free Trade Agreement (FTA) or duty preference program instructions.
Updated Certificates of Origin
Ensure the availability and accuracy of Certificates of Origin for duty preference claims under FTAs.
Evaluate Tracking of Assists
Establish a system to track and allocate assists correctly, periodically checking for accuracy.
Evaluate Documentation and Recordkeeping Processes
Maintain complete and accurate records of all import and export transactions, including shipping documents, invoices, and correspondence.
Conduct Periodic Compliance Checks
Regularly conduct post-entry confirmations of a sample of entries to ensure accuracy and mitigate errors.
Coordinate with Freight Forwarders and Customs Brokers
Engage with third parties to ensure consistent adherence to Customs requirements.
Evaluate Tariff-Saving Opportunities
Consider Holding Products in a Bonded Warehouse
Explore the option of storing products with duties in bonded warehouses to defer duty payments.
Duty Drawback
Investigate the possibility of duty drawback for certain transactions to obtain refunds of previously paid tariffs.
Foreign Trade Zone (FTZ)
Utilize FTZs to store, exhibit, assemble, manufacture, or process products without incurring duties.
Temporary Importation Under Bond
Explore the use of Temporary Importation Under Bond for duty savings.
Use of First Sale Rule
Consider leveraging the First Sale Rule, especially for imports from China, while ensuring strict compliance with requirements.
Evaluate Customs Housekeeping Issues
Sign up for ACE
Promptly sign up for Automated Commercial Environment (ACE) to enjoy various advantages, including decreased administrative costs.
Request Census Bureau Data
To comply with Export Administration Regulations (EAR), request Census Bureau data annually for the prior 12 months.
Bond Sufficiency
Regularly review the sufficiency of continuous entry bonds to avoid CBP declaring bonds insufficient.
Listing Multiple Principals on the Same Bond
Consider the implications of including multiple entities on the same bond for potential cost savings.
Customs Broker Powers of Attorney
Monitor and update customs powers of attorney granted to brokers, revoking any unnecessary authorizations.
Update Names and Addresses on File with CBP
Ensure accuracy and compliance with CBP importer tracking requirements by reviewing and updating information on file.
Manifest Confidential Treatment
File for government confidentiality to protect import data from being accessed by competitors.
Trademark and Trade Name Protections
Explore CBP’s role in protecting registered trademarks and trade names, taking necessary steps to safeguard intellectual property.
Conduct Training
Provide Periodic Training on Customs Requirements
Ensure relevant personnel, including those in charge of customs compliance, procurement, and shipping/logistics, receive periodic training on essential customs topics.
Amidst the complexities of customs compliance, choosing Alba as your logistics partner can make all the difference. Our seasoned experts understand the intricacies of international trade regulations and can guide you through the evolving landscape. Whether it’s navigating changes in HTS codes, managing quota preparations, or ensuring seamless documentation, our team is dedicated to keeping you compliant.
At Alba Wheels Up!, we go beyond logistics – we’re your strategic partner in international trade. Trust us to not only meet your shipping needs but also to keep you ahead of the curve in customs compliance. In a world where adherence to regulations is paramount, choose Alba Wheels Up! for a smooth and compliant journey into 2024.
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