Advanced Customs Compliance
Training Course

Presented by:

The Law Offices of George R. Tuttle
and the Professional Association of
Exporters and Importers

Course Overview

• Customs Organization and the emphasis on Compliance


• Resource Documents: The Customs Web Site, The HTSUSA, The Explanatory Notes, the Customs Regulations, and related publications and databases


• Duty savings, strategies, programs and techniques

• Reasonable Care, Informed Compliance, and Enforced Compliance


• Focused Assessment Audits, Customs Investigations, Requests for Information


• Company Internal Control Procedures and compliance manuals

• Types of entries: Consumption, warehouse, T.I.B., and FTZ


• The order and entry process, Customs invoicing requirements


• Post entry amendment procedures: PEAS, SILS, Reconciliation's, and Prior Disclosures.


• Quantities (overages and shortages)


• Record keeping requirements, the (a)(1)(A) list, and penalties

• Understanding the transaction: Problems and Pitfalls in the entry documents vs. the commercial billing and payment procedures


• Transaction value and determining the price paid


• Appraisement at resale prices in the United States


• Identification of sales for export and the Nissho-Iwai case


• Related Party transactions and transfer pricing issues,


• Additions to the price paid or payable: assists, including components, tools, dies, molds, machinery research design development, freight costs, packing


• The alternative basis of valuation

• Entry requirements and the deposit of estimated duties Classification of Merchandise Under the Harmonized System


• Principles of classification: the GRI's and Explanatory Notes


• Classification principles relating to chapters 84, 85 and 90, including the functional unit and essential character rules.


• Recent classification issues and rulings relating to Chapters 84, 85 and 90

• Substantial transformation


• Change of Heading


• Compliance with the country of origin rules, including invoicing requirements


• Duty Exemptions and Preference Programs Eligibility Requirements


• Chapter 98: Articles exported for assembly, or repair or alteration; returned defective precuts, and Temporary Importation Bonds.


• North American Free Trade Agreements (NAFTA)


• Generalized system of preferences (GSP)


• Caribbean Basin Initiative (CEBRA)


• Israeli Free Trade Agreement (IFTA)


• The African Free Trade Agreement

• Civil penalties can be assessed for false documentation: 19 U.S.C. § 1592


• Limitation of Penalties by Prior Disclosures: procedures and benefits


• Liquidated damage claims and the posting for violation of the import bond


• Potential criminal liabilities

• Marking rules


• Marking and exceptions to the marking rules


• Invoicing requirements

• Counterfeit trademarks or copyrights and seizures and additional civil penalty assessments


• Confusingly similar trademarks for copyrights and seizures


• Under the entry process or after valuation, antidumping and countervailing duty requirements

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