customs-trade-compliance

HS classification applies the General Rules of Interpretation in strict order, starting with GRI 1 using heading terms and Section/Chapter notes. Identify the good's full technical specification first, determine the Section and Chapter, then validate at the subheading level with GRI 6 and check binding rulings.

USMCA qualification requires meeting product-specific rules of origin in Annex 4-B, typically a tariff shift or minimum regional value content. Trace all non-originating materials through the bill of materials, calculate RVC using the transaction value or net cost method, and prepare a certification with nine prescribed data elements.

DAP means the seller bears all risk and cost to the destination but excludes import clearance and duties, while DDP includes import duties and taxes, requiring the seller to act as importer of record. DDP also creates customs valuation considerations since duty included in the invoice price can cause a circular valuation problem.

Assess match quality through name similarity, address correlation, country nexus, and alias analysis before blocking or clearing the transaction. Escalate true positives and ambiguous cases to compliance counsel immediately, and document the screening tool, match details, adjudication rationale, and disposition for at least 5 years.

File a prior disclosure under 19 CFR § 162.74 before CBP initiates an investigation or issues a pre-penalty notice. Doing so caps penalties at interest on unpaid duties for negligence violations, making it the most effective penalty mitigation tool available.

Section 321 de minimis entry waives duty but does not eliminate quota, antidumping/countervailing duties, or partner government agency requirements. CBP may aggregate multiple same-day shipments to the same consignee, so restructuring shipments to stay below the threshold creates evasion risk.