A Federal Register Notice for Monday March 10, 2014 modifies previous CBP notices regarding the Centers of Excellence and Expertise (CEE) “test” that has been underway since August of 2012. The test, broadly speaking, is a formalization of an “account” based approach to handling an importer’s Customs declarations so that importers receive consistent treatment to their import transactions across the country, and at the same time avail themselves of the best expertise within CBP as it pertains to their particular industry.
The notice reminds us of the following:
Divvying up the tariff schedule by “industry” and the responsibilities of importation related functions has never been a simple task within CBP and its predecessor Customs Service. Industries are not neatly contained in one Chapter or Section of the Harmonized Tariff Schedule (HTS), and the complexity of import regulations don’t lend themselves to open and shut decision making for any given type of import declaration. Lastly, there are the logistical, resource, and political realities that have to be dealt with anytime work is parceled out within any organization, be it government or private.
The notice itself can be found here and clearly describes the modifications to the test, http://www.gpo.gov/fdsys/pkg/FR-2014-03-10/html/2014-05115.htm, but here is a condensed summary:
I. Modification of the Scope of Coverage for Certain Centers
a. Automotive & Aerospace Center
Adds tariff heading 8511 which was previously covered by the Machinery Center
b. Base Metals Center
Removes tariff headings 7414, and 7309 through 7311
Adds tariff headings 7415, and 8307 through 8311
c. Consumer Products & Mass Merchandising Center
Removes tariff heading 7013
Adds heading 9619, 8210, and 8539
d. Industrial & Manufacturing Materials Center
Removes tariff heading 4414 and 4815
Adds headings 2501 through 2530, 7013, 7309 through 7311, and 9406
e. Machinery Center
Removes tariff heading 8485, 8210, 8539, 8307 through 8311, 8511, and 9406
f. Petroleum, Natural Gas & Minerals Center
Removes tariff headings 2501 through 2530
Adds heading 3826
II. Modification to the Types of Entries Processed by the Centers
• In addition to the consumption entry types already processed by the Centers, it includes the entry types for Informal Entries (type 11), Temporary Importation Under Bond (type 23), and Trade Fair (type 24).
• There are also promises for additional entry types to be transitioned in the future, including Reconciliation entry type 09.
• Regarding Anti-Dumping and Countervailing Duty (entry types 03), the call is to have entries filed before the importing participant joined the test to be processed by the ports, and those entries filed after joining the test to be processed by the Centers.
III. Waiver of Additional Regulation for the Center Test
Waives Sec. 10.847(c) of the regulations so that when a test participant discovers that they made an erroneous duty free claim under Sec. 10.847(a), they can file a correction with the Center instead of with the port of entry.
IV. Submission of Responses to Requests for Information (CBP Form 28) and Notices of Action (CBP Form 29)
Clarifies that test participants must respond to these Customs Forms electronically. (To me it is not clear whether they mean through the ACE portal or simply through Email.)
The notice reminds us of the following:
Divvying up the tariff schedule by “industry” and the responsibilities of importation related functions has never been a simple task within CBP and its predecessor Customs Service. Industries are not neatly contained in one Chapter or Section of the Harmonized Tariff Schedule (HTS), and the complexity of import regulations don’t lend themselves to open and shut decision making for any given type of import declaration. Lastly, there are the logistical, resource, and political realities that have to be dealt with anytime work is parceled out within any organization, be it government or private.
The notice itself can be found here and clearly describes the modifications to the test, http://www.gpo.gov/fdsys/pkg/FR-2014-03-10/html/2014-05115.htm, but here is a condensed summary:
I. Modification of the Scope of Coverage for Certain Centers
a. Automotive & Aerospace Center
Adds tariff heading 8511 which was previously covered by the Machinery Center
b. Base Metals Center
Removes tariff headings 7414, and 7309 through 7311
Adds tariff headings 7415, and 8307 through 8311
c. Consumer Products & Mass Merchandising Center
Removes tariff heading 7013
Adds heading 9619, 8210, and 8539
d. Industrial & Manufacturing Materials Center
Removes tariff heading 4414 and 4815
Adds headings 2501 through 2530, 7013, 7309 through 7311, and 9406
e. Machinery Center
Removes tariff heading 8485, 8210, 8539, 8307 through 8311, 8511, and 9406
f. Petroleum, Natural Gas & Minerals Center
Removes tariff headings 2501 through 2530
Adds heading 3826
II. Modification to the Types of Entries Processed by the Centers
• In addition to the consumption entry types already processed by the Centers, it includes the entry types for Informal Entries (type 11), Temporary Importation Under Bond (type 23), and Trade Fair (type 24).
• There are also promises for additional entry types to be transitioned in the future, including Reconciliation entry type 09.
• Regarding Anti-Dumping and Countervailing Duty (entry types 03), the call is to have entries filed before the importing participant joined the test to be processed by the ports, and those entries filed after joining the test to be processed by the Centers.
III. Waiver of Additional Regulation for the Center Test
Waives Sec. 10.847(c) of the regulations so that when a test participant discovers that they made an erroneous duty free claim under Sec. 10.847(a), they can file a correction with the Center instead of with the port of entry.
IV. Submission of Responses to Requests for Information (CBP Form 28) and Notices of Action (CBP Form 29)
Clarifies that test participants must respond to these Customs Forms electronically. (To me it is not clear whether they mean through the ACE portal or simply through Email.)