CBP Targeted Enforcement - Section 301 Duties

Why Should You Attend:

The recent developments in the on-going trade dispute with China have led to imposition of 301 duties of 25%, or in some cases 10% until January 1, 2019 when they will also be 25%, on some products from China. Importers have taken steps to avoid classifying products in provisions that are subject to the 301 duties, sometimes without justification. Also, some companies have engaged in attempts to change the country of origin (COO), in some cases not correctly. CBP has publicly cautioned importers and increased enforcement staff to examine instances where past import classifications and COO have been altered.

Learning Objectives:

• General compliance with CBP regulations and laws.
• Identifying risk areas
• Justifying changes in entry practices
• Justifying apparent changes in sourcing or supply chain
• Assess the need for prior disclosures
• Record keeping that justifies changes
• Self-review

Areas Covered in the Webinar:

• 301 implementation
• Efforts to minimize impact through logistics
• Efforts to change HTSUS classification
• Efforts to “substantially transform” product to claim a different COO
• Changes in sourcing for COO purposes
• Documenting all steps that have led to a change in HTSUS or COO
• Where are possible compliance vulnerabilities
• Evaluating risks
• What to do if contacted by CBP

Who Will Benefit:

• Import compliance professionals
• Brokers
• Attorneys
• Logistics managers
• Purchasing managers
• Supply chain managers

Raymond Sullivan
Principal and Founder, Law Offices of Rayond F Sullivan

Raymond F. Sullivan is an attorney with over 30 years of practice in customs law. His practice encompasses customs penalties, seizures audits and enforcement activities, as well as classification and valuation issues – including litigation of these issues. He regularly conducts evaluations of importer compliance systems and processes; and, has developed and implemented import compliance programs for a number of importers. Mr. Sullivan has written numerous articles on customs and international trade law; and, has served on Law 360’s International Trade Editorial Advisory Board.

Mr. Sullivan is a former import specialist and special agent with US Customs. He is a member of the bar in Maryland, New York and the District of Columbia; and, litigates matters before the US Court of International Trade.

Follow us :