Customs Compliance Evaluations

The U.S. Bureau of Customs and Border Protection (CBP) rules and regulations are constantly changing forcing importers to be ever vigilant on satisfying the legal requirements of importing merchandise into the United States. Piña Customs Advisory Services (PCAS) will review your operations to determine procedural weaknesses and make recommendations so that you can be prepared in the event you are selected for a Focused Assessment or Regulatory Audit.

During the compliance assessment we will examine and evaluate the following:

• In general terms, the company’s understanding of its responsibilities - as an importer of record - under the U.S. Customs Informed Compliance and Modernization Act of 1993 (Public Law 103-182 Stat. 2057).
   

• The company’s compliance with the requirements of importing goods into the U.S. under preferential tariff provisions such as tariff items 9801.00.10, HTSUS, 9802.00.50, HTSUS and 9802.00.80, HTSUS.
   

• The company’s compliance with the rules and regulations regarding importing articles into the U.S. as originating goods as stipulated in Part 181, Customs Regulations- The North American Free Trade Agreement.
   

• The tariff classification - under the HTSUS - of the articles that are imported into the United States.
   

• The valuation of the company’s importations into the United States. Are imported goods valued in accordance with the Customs valuation principles stipulated in the Trade Agreements Act of 1979?
  
  Whether the country of origin of the goods imported into the U.S. is being determined in accordance with the Part 102, Customs Regulations – Rules of Origin?
   

• Whether the goods imported into the U.S. are marked in accordance with Part 134 of the Customs Regulations- Country of Origin Marking?
   

• The company’s record keeping system including record retention regarding maintenance for the required time period and accessibility for tracking audit or validation purposes.
   

• Import documentation and internal supporting records including foreign purchase orders, assists to foreign suppliers, royalties, selling commissions, proceeds from subsequent resale, indirect payments and foreign packaging costs.
   

• We will review what incoming monitoring system the company has in place to detect errors in quantity, value or classification before imported goods are received into inventory.
   

• We will want to review any internal import procedures manuals that are in existence and speak to the person(s) maintaining the manual(s).

During the compliance review we will speak to people in the following departments: Finance, Purchasing, Traffic, Receiving, Customs and any other departments which play a role in the importation of foreign goods into the U.S. We will want to interview key people involved in merchandise description, classification, valuation, and country of origin determination to determine their understanding of the U.S. Customs Reasonable Care Checklist.

After the compliance review we will provide the client with a written report notating findings and recommendations.