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Has your Company Reviewed your Tariff Classifications Recently?

It’s no secret that the current administration has levied record amounts of duty on imports since 2016, which makes tariff classification vitally important.

The proper classification of a commodity is the driver for nearly every component in a cross border transaction.  This includes duty assessment, documentary requirements, and the data that may need to be transmitted to satisfy partner government agencies like the U.S. Food and Drug Administration, Environmental Protection Agency, and the Department of Agriculture.  Thirty-one percent of this past year CBP requests were validating classifications.

Further, the Office of the U.S. Trade Representative has begun offering exclusions to the China 301 tariffs.  These exclusions are driven by the tariff number.  In order to qualify for the exclusion and successfully obtain a refund of the duties, the goods must be both properly classified and meet the requirements set forth in the individual exclusion.  If your goods are misclassified, the process of claiming an exclusion becomes much more difficult.

We encourage our clients to periodically review the tariff codes that are used for their goods.  The tariff schedule can change multiple times per year, so a periodic review should be a part of your company’s compliance protocol. Since January 1st of 2020, The United States International Trade Commission (USITC) has already made four (4) revisions to the schedule.  The current tariff schedule can be found here.

Even if your company has ‘always used this tariff number’ or if the tariff number as ‘provided by the supplier,’ it may not be correct. Your company is responsible for ensuring the tariff number is accurate.  These types of proactive, internal protocols will give your company a greater knowledge of costing and requirements necessary to successfully navigate trade with the United States.

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COVID-19 is a global challenge. Keeping our supply chains moving is important for maintaining the health and wellbeing of citizens and businesses. While the Canada - U.S. border is now closed to non-essential traffic, it is still open for trade and commerce. We are committed to doing our part for global supply chains.

We are protecting the health and safety of our employees. They are working from home, except for critical functions that require certain equipment or managing paper/courier flow. In those cases we are following social distancing guidelines.

We are open and available to assist you, and key players in your supply chains. Our dedicated staff are available 24/7 and our brokerage and logistics experts are available to help you make adjustments to your supply chain, if necessary.

We encourage you to check out the government programs available to families, businesses, exporters and importers. And, while respecting the need for social distancing we encourage everyone, including our staff, to reach out and remain connected to family, friends, colleagues and customers.

Stay safe.

Peter Willson
Chairman & CEO
Willson International

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