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, 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 regional value content threshold. Trace all non-originating materials through the bill of materials and calculate RVC using the transaction value or net cost method.

Assess match quality through name similarity, address correlation, and country nexus before acting, since roughly 95% of hits are false positives. Escalate true positives and ambiguous cases to compliance counsel immediately and document the adjudication rationale.

The first sale rule is recognized by US CBP for related-party transactions but not by the EU, which values goods on the last sale before importation. Using first sale valuation in the EU creates duty underpayment exposure.

File a prior disclosure before CBP initiates an investigation or issues a pre-penalty notice to cap penalties at interest on unpaid duties for negligence. The disclosure must identify the violation, provide correct information, and tender the unpaid duties.