What is the “First Sale” Rule and How Does it Affect Me?
The First Sale Rule applies in circumstances such as the example above. A US company places an order with a middleman in the US. The middleman in turn subcontracts to a foreign supplier. The supplier then ships the product either to the middleman or to the original US company that placed the order, meaning either could be the importer of record. The entered value could be the amount on the original purchase order or the price paid by the middleman to the foreign supplier.
Challenges Ahead! – Requesting to be Excluded From the Xinjiang Exclusions
In April of this year U.S. Customs & Border Protection (CBP) issued Headquarters Ruling H330077. The ruling was in response to a protest filed by an importer that had a shipment of wearing apparel excluded from entry under a Withhold Release Order (WRO) at the port of Newark, NJ. The wearing apparel was processed from cotton produced in India, made into yarn and fabric in China, and converted to wearing apparel in Cambodia. None of the parties to the transaction were located in the Xinjiang Region of China.
Customs and Border Protection
Dealing with CBP. Braumiller Consulting Group can help.
Top Secret
Customs CF-28 require a full and proper response. Braumiller Consulting Group can help.
Need Help with China Imports?
International trade and customs compliance with imports from China, navigating section 301, and dealing with WRO and forced labor are complicated. Conducting business with China is not getting easier. Braumiller Consulting Group can help.
Hot Topics In International Trade: Customs Broker Modernization Regulations 19 CFR 111
Bruce Leeds discusses the changing landscape for customs brokers amid changes recommended by COAC (Commercial Customs Advisory Committee) which is an advisory committee to U.S. customs. The result are changes to modernize regulations through an overhaul of part 111 of the customs the regulations, including responsible supervision and control.
Forced Labor
WRO and ULFPA detentions are happening much more often with China, Malaysia and Vietnam. The supplier to your supplier is where you may often be unfamiliar with the source of manufacturing and whether forced labor is involved. How to overcome the obstacles regarding importing a product to the U.S. from these countries. Braumiller Law Group can help.
Braumiller Law Group Shipping Containers Exam
There are three main exams customs will conduct to determine whether they will release or confiscate a shipment on hold. One is the x-ray exam or VACIS exam, the second is the tail gate exam or break the seal and enter, and the third is the intensive exam where they empty the container and open all contents. Not passing the exam can be very expensive. Braumiller Consulting Group can help.
Customs Brokers: Giving Credit to Accreditors
U.S. Customs & Border Protection (CBP) published the Final Rule on continuing education for individual customs broker license holders in the Federal Register on June 23, 2023. This Final Rule made several changes to Part 111 of the Customs Regulations and imposed a continuing education requirement on individual license holders.
Driving You MAD – Customs Issues in Mergers Acquisitions & Divestitures
When one company buys another there are typically two ways the purchased company will be treated: (1) It will be incorporated into the parent company and will no longer exist as a separate entity. (2) It will become a separately incorporated subsidiary of the parent company and retain its IRS number.