August 2018

Customs warns importers of increasing cases of identity theft (Repeated from January – we have had an importer recently report this problem!)

Customs officials last year reported a rise in importers’ identity being hijacked by criminals and used in unlawful imports.  The criminals obtain an importer’s IRS employer identification number (EIN), which is used by Customs as the “importer number”.  The criminals then make entry using that information.  When Customs inspects the shipment and finds contraband, they seize the shipment and notify the legitimate importer.  The legitimate importer must then prove it was not their shipment.  This has been very difficult and expensive for some importers, and we don’t want that to happen to our good customers. We have long urged importers to keep a spreadsheet with ALL imports identified by at least entry number, P.O. number, bill of lading number, and date.  If we write your bond, we can easily furnish you a list of all imports made nationwide under your importer number, which you can compare against your spreadsheet.  If we do not write your bond, you should contact the surety and have them furnish you with a similar report.  We urge ALL importers to check their imports in this manner at least twice a year. If you find this problem, please call us immediately.

Trump administration requesting more employees and funds for ADD/CVD cases (From American Shipper)

The Commerce Department’s first self-initiations of antidumping and countervailing duty investigations in more than a quarter century have signaled to potential petitioners for AD/CV duty relief that the Trump administration is taking a staunch approach to trade enforcement, observers said recently.  According to a July 24 Commerce press release, the department at that point had started 120 new AD and CV duty investigations under the Trump administration, 216 percent more than the 38 initiations started throughout the first 539 days of the Obama administration, a similar time window.
   “Petitioners’ counsels and law firms are busier than ever,” said Tom Sneeringer, who retired June 30 from his position as president of the Committee to Support U.S. Trade Laws. “And I think what’s happening is it’s feeding on itself in the sense that, as more and more remedies are won, people who have wondered if they could get a remedy are calling lawyers and saying, ‘Let me tell you what my situation is,’ because there is a new confidence in winning these cases.” For more information please go to

https://www.americanshipper.com/main/fullasd/compliance-360-signs-of-trade-enforcement-times-72140.aspx

ADD/CVD reminder (Repeated from April)

We continue to see a steady increase in the number of anti-dumping and countervailing duty complaint investigations being brought by the Department of Commerce.  This is especially true for non-market economies, particularly China and Vietnam. It is the responsibility of the importer of record to know if/what ADD/CVD cases apply to your merchandise. Further, we MUST get special permission from your surety for any entry involved with ADD/CVD, and the surety will usually require collateral for the full value of your bond.  The collateral can be either a cash deposit or standby letter of credit.  To avoid being assessed unexpected costs of ADD/CVD on your imports, we urge you to frequently check the list of Commerce investigations that can be found at

http://enforcement.trade.gov/stats/inv-initiations-2000-current.html

Alternatively, you can engage a service that monitors ADD/CVD cases for you.  Their fees vary, but they are pricey. If you prefer to engage a service, please contact us for a referral.

Merchandise processing fees to increase

U.S Customs & Border Protection has issued increases for the minimum and maximum MPF for fiscal 2019.  They are minimum $26.22/maximum $508.70 beginning October 1, 2019. The Informal MPF (class code 311) will increase to $2.10.

Registration Period for Food and Medical Device Facilities Approaching (From Sandler, Travis)

U.S. and foreign food and medical device facilities that do not properly renew their registrations with the Food and Drug Administration can be locked out of the U.S. market. Renewals for both types of facilities are due this year starting Oct. 1.

 Under the Food Safety Modernization Act, all domestic and foreign facilities that manufacture, process, pack, or store food, food ingredients, pet foods, or dietary supplements are required to renew their registrations with the FDA every even-numbered year. When registering, foreign food facilities must also designate a U.S. agent, a person or entity that is located or maintains an office in the U.S. and acts as the facility’s domestic representative through which all communication with the FDA takes place. U.S. agents must confirm that they have agreed to serve as such and the FDA will not confirm a registration or provide a registration number until the U.S. agent has provided this confirmation. For more information, please go to

https://www.strtrade.com/news-publications-food-medical-device-facility-registration-080618.html

CBP issues alcohol tax refund rule (From American Shipper)

U.S. Customs and Border Protection on Thursday published an interim final rule (IFR) that will enable the agency to refund alcohol excise taxes importers paid prior to CBP assigning them a reduced tax rate or tax credit for alcoholic beverages, pursuant to the Craft Beverage Modernization Act (CBMA) portion of tax reform legislation signed into law on Dec. 22.
   The IFR is effective as of Thursday, and CBP is accepting comments on it through Oct. 15.
   Subject to requirements, importers may now obtain the benefit of a lower tax rate through CBMA by filing a refund claim with CBP.
   For an importer to be eligible to receive a reduced tax rate or tax credit under the CBMA, the importer must be able to substantiate that the foreign producer assigned an allotment of its reduced tax rate or tax credits to the beer, wine, or distilled spirits imported by that importer, CBP said. For more info, please go to

https://www.americanshipper.com/main/fullasd/cbp-issues-alcohol-tax-refund-rule-72300.aspx (This site no longer accessible).  Use: https://csms.cbp.gov/viewmssg.asp?Recid=23602&page=&srch_argv=18-000403&srchtype=all&btype=&sortby=&sby=

Contact us with any questions.

Lee Hardeman       LeeH@LHCB.com                Direct: 404-477-3452

Sandy Cato           SandyC@LHCB.com                Direct: 404-477-3454

Brittany Albaneso  BrittanyA@LHCB.com            Cell: 404-401-5950

If you do not wish to continue to receive our newsletter,  please  email me at  leeh@lhcb.com and put “Unsubscribe” in the subject line.