Customs & Trade Compliance

When to Use

Use to prepare classification, origin, valuation, documentation, screening and post-entry review analyses for a specified shipment and jurisdiction. Draft broker instructions or questions; do not file entries, certify origin, release held goods, pay duties, block property or contact regulators without authority.

Establish the Applicable Facts

Obtain the importing/exporting jurisdiction, entry date and procedure, actual product specifications and manufacturing history, parties/ownership, end use, route, invoices, costs and declared Incoterms version/named place. Record the applicable tariff/regulation version and source checked. Separate classification, non-preferential origin, preferential origin, export jurisdiction, export-control classification and sanctions: an HS code does not decide all six.

Workflow

1. Classification: Read the current heading text and legal Section/Chapter

Notes under GRI 1. Apply further GRIs where applicable, including incomplete goods/mixtures, specificity, essential character and numerical order. GRI 2(b) does not itself select the essential-character material. Check special legal machine/parts provisions before generic essential-character reasoning. GRI 6 compares subheadings at the same level. Resolve national import/export suffixes separately; do not classify from a marketing name or an invented ruling.

1. Origin: Document actual production and inputs. Shipping/repacking through

another country is not proof of changed origin. Apply the particular origin rule, AD/CVD scope or FTA annex rather than a universal value-added percentage. For preference verify production-period BOM, permitted calculation method, cumulation, tolerance, transport and evidence/certification requirements.

1. Valuation: Apply the jurisdiction's valuation hierarchy and documented

adjustments. Related parties do not automatically invalidate transaction value, and a tax transfer-pricing study does not automatically validate it. Assess actual assists, royalties, proceeds, discounts and costs. Incoterms allocate contractual obligations; they do not prescribe the customs method.

1. Screening and export controls: Check current applicable lists, ownership

and control rules, item jurisdiction/classification, destination, end user, end use, licences and red flags. A no-hit name search is not permission to ship. Put unresolved cases on an operational hold for the authorised compliance owner. Distinguish that hold from legally blocking or rejecting a transaction.

1. Documentation: Reconcile invoice, packing list, transport documents, origin

evidence, entry data and relevant product-agency requirements. Determine actual filing/claim deadlines and required data for the entry type; do not presume all invoice checklists, ISF timings or certifications apply identically.

1. Corrections: Preserve entry/payment records and actual liquidation dates.

Have the broker/counsel identify the applicable correction, reconciliation, protest, preference or disclosure route. A normal correction is not automatically a legally valid prior disclosure.

Concrete Corrections to Common Shortcuts

• For US transaction value, international freight/insurance are generally

excluded subject to documented applicable rules; EU customs value generally includes transport/insurance to the place of introduction. Do not reverse these or automatically declare a CIF/DDP invoice total. Import VAT can have a different base from customs duty.

• USMCA RVC formulas are 100*(TV-VNM)/TV and 100*(NC-VNM)/NC with the

agreement's definitions and product-specific thresholds. A lower denominator does not inherently raise RVC. Holding VNM=40 fixed, TV=100 gives 60%, whereas NC=80 gives 50%. Choose only a method permitted for the actual good.

• An omitted USMCA preference claim under 19 USC 1520(d) generally has a one-year

deadline from importation, not one year from liquidation. Do not promise recovery of all historical entries using a generic protest window.

• Do not plan around the historical US $800 duty-free parcel assumption. CBP

suspended the relevant de minimis treatment for all countries effective August 29, 2025; verify the current procedure for the actual entry date.

• Use the current UK Sanctions List; the old OFSI consolidated list stopped

updating on January 28, 2026. Verify list/ownership rules at transaction time.

• Retention is regime-specific: do not apply a universal five-year limit to OFAC

records, whose general requirement was extended to ten years. Preserve legal holds and longer contract/program obligations.

Example Output

For a hypothetical CIF invoice, show goods price, separately evidenced freight and insurance, any assists/royalties, proposed US and EU adjustments and the supporting legal basis. Label the result draft valuation for broker review.