A thorough knowledge of various types of product classifications are essential for anyone involved in global trade. Determining Tariff Classifications are in a very real sense - just the beginning. In addition, a product can often fall under the jurisdiction of other government agencies as well. Determining necessary classification applicability and the evaluation of product within each designation is a skill that is developed with experience and maintained by use.
Harmonized Tariff Schedule (HTS) / Schedule B
The tariff classification of imported merchandise governs the applicable duty rate. Importers must provide the proper ten-digit classification number to U.S. Customs and Border Protection (CBP) when an entry is filed. It is the importer's responsibility to exercise reasonable care in the classification of merchandise. Errors due to a lack of reasonable care can result in significant fines and penalties. In other words don't guess! It can be costly.
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In order to accurately classify any commodity, a detailed legal analysis and comprehensive knowledge of the USHTS, Customs rulings and practices, and a wealth of experience comes into play. WD can help you assess the correctness of a tariff classification for your products, and prepare ruling requests to submit to (CBP) advocating for a specific tariff classification. Our Boot Camp Basic Training can help you understand the basics of the HTS system globally and give you a platform for implementing processes and procedures to ensure that merchandise is reviewed and classified correctly.
ECCN -Export Control Classification Number
All parties to U.S. export transactions must ensure their exports fully comply with all statutory and regulatory requirements. Compliance not only involves controlled goods and technologies, but also restrictions on shipping to certain countries, companies, organizations, and/or individuals.
In order to complete an accurate classification, you must have a technical understanding of your item, and you need to be familiar with the structure and format of the Commerce Control List (CCL).
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Export regulations consider the following criteria in the transaction:
1) What is the ECCN of the item?
2) Where it is going?
3) Who is the end-user?
4) What is the end-use?
While the majority of U.S. commercial exports do not require a license, the first step in this process is determining the correct classification of your item.
An Export Control Classification Number (ECCN) is an alphanumeric designation used in the Commerce Control List to identify items for export control purposes. An ECCN categorizes items based on the nature of the product, (type of commodity), technology or software and its respective technical parameters. Once the ECCN has been identified, you can determine the reasons for control of the item, which transactions may require an export license based on the country of destination, and which license exceptions, if any, may apply.
We can help exporters determine the jurisdiction of a commodity, classify the commodity, and determine if an export license is required or if a license exception or exemption is available. We have successfully obtained numerous commodity classification determinations on behalf of our clients.
USML - United States Munitions List
Recent Export Reforms (and more on the way) has changed the way defense items are evaluated. The stated goal has been to put "higher fences around fewer items." The new system is set up to be very intelligent and tailored to the specifics. So the first question when doing a jurisdictional review under the revised rules will be - Is the item still subject to the ITAR? The ITAR still trumps EAR under the revised rules, so USML is still the first evaluation before stepping over to the Commerce Control List.
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If an item is not specifically enumerated within the twenty-one categories on the revised USML, and does not fall under a "specially designed" catch-all, your review of the USML ends here. You will now move to the CCL and determine whether the item is listed in the new "600 series" of the CCL. Sound a bit confusing? It can be. Especially when you add in the catch and release approach applied to the "specially designed" definition of the EAR.
WatsonDavis is here to help you sort out some of the significant regulatory changes, as well as new compliance obligations and responsibilities on the part of the exporter. The important prerequisite of proper classification is even more important now in light of the recent and upcoming revisions to the USML and the CCL.
To find out more how WatsonDavis can help you with the evaluations and filings contact us
FDA - Food and Drug Administration
FDA is charged with the primary responsibility of protecting the public.
The basics of FDA to the import Industry is aimed at improving communication and making information about the regulatory process more accessible in a user-friendly format. There are several new and improved tools that we can use to assist in determining if your products required FDA clearance prior to entering US territory.
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Each area of FDA oversight is detailed and clearance codes communicated to US Customs Service is key to expediting your qualified products into the country. WD can effectively review and evaluate the FDA standards of your product and make sure the proper classification is made available to US customs.
The FDA is responsible for:
Assuring the safety, effectiveness, quality, and security of human and veterinary drugs, vaccines and other biological products, medical devices, most of our nation's food supply, all cosmetics, dietary supplements, and products that give off radiation
Assuring that certain foods are safe, wholesome, sanitary and properly labeled.
Protecting the public from electronic product radiation
Assuring cosmetics and dietary supplements are safe and properly labeled
Regulating tobacco products