Verifying your References
Has a responsible and knowledgeable individual within your organization verified your customs documentation ensuring it is complete and accurate?
Discuss with an Expert
If you are working with a Customs Broker (like us) to assist you in complying with customs requirements, have you discussed your imports in advance and provided them with complete and accurate information about the import transactions? Do you follow the advice received and keep a written record of that advice?
Maintain a Compliance Program
Do you have a customs compliance program and procedures in place? Is it accessible to all employees involved in the import process and are they following it?
Have you verified if identical transactions or merchandise are being handled differently at different ports? If so, have you brought this fact to the attention of CBP officials?
Merchandise and Tariff Classifications
Do you know or have you established a reliable procedure to ensure that you know what you ordered, where it was made, and manufacturing details?
Do you know or have you established a reliable procedure to know the price paid or payable for your merchandise? Do you know the terms of sale (i.e. Incoterms®), whether there will be rebates, tie-ins, indirect costs, additional payments, whether assists were provided, commissions or royalties paid? Are amounts actual or estimated? Are you and the seller related parties?
Country of Origin
Have you taken reliable measures to ascertain the correct country of origin for the imported merchandise? Have you obtained a “ruling” from CBP regarding the proper marking and country of origin of the merchandise? If so, have you established reliable procedures to ensure that you followed the ruling and brought it to CBP’s attention?
Intellectual Property Rights
Have you established a reliable procedure that permits you to determine whether your merchandise or its packaging bears or uses any trademarks or copyrighted matter or is patented? If so, do you have a legal right to import those items into, and/or use those items in the United States?
Have you taken reliable measures to ensure imported goods are not produced wholly or in part with convict labor, forced labor, and/or indentured labor (including forced or indentured child labor)? Have you established a reliable procedure of conducting periodic internal audits to check for forced labor in your supply chain?