Customs Compliance: Where Do You Start?

Supply chain disruptions haven’t been the only significant events in our industry the last couple years.

Many significant pieces of shipping legislation were passed, and enforcement of Customs penalties in general is on the rise.

The Ocean Shipping Reform Act of 2022 and the Uyghur Forced Labor Prevention Act — among other legislation — have brought to light the complexity and gravity of complying with U.S. Customs regulations.

The importer of record is ultimately responsible for exercising reasonable care in their supply chain. But we’re here to help!

An importer of record’s failure to exercise reasonable care could delay release of the merchandise and, in some cases, could result in the imposition of penalties or, in certain instances, referral for criminal enforcement…Section 484 of the Tariff Act, as amended, requires an importer of record to use reasonable care…Despite the seemingly simple connotation of the term reasonable care, this explicit responsibility defies easy explanation.

Informed Compliance Publication Reasonable Care (cbp.gov), pgs. 3, 7

Customs Compliance Resources

1. CBP

CBP has provided a number of resources to help shippers understand what is required of them.

Informed Compliance Publications (ICPs)

These publications address “What Every Member of the Trade Community Should Know About”…

  • Their goods being imported | these ICPs are divided into categories such as apparel, machinery, consumer products, pharmaceuticals, and so on.
  • General topics related to shipping | tariff classifications, Customs value, recordkeeping, etc.

Withhold Release Orders and Findings List

CBP’s list of WROs and Findings identify the commodities from particular regions that CBP has reason to believe would likely be in violation of forced labor laws, and that will be subject to exclusion and/or seizure upon entry into the United States.

2. Trade law firms

Law firms that specialize in Customs and Trade Compliance can be a wealth of knowledge about current or pending legislation, and can be a valuable resource if you are ever in need of legal assistance.

The law firm of Sandler, Travis & Rosenberg, P.A., for example, issues newsletters, articles, and daily podcasts on supply chain and compliance topics.

While general updates do not constitute legal advice, these firms often have a deeper understanding than other public sources of how supply chain legislation is actually implemented, and what to expect or do next.

They also keep track of legislation that does not get as much media coverage, and can help importers be informed about issues and deadlines pertaining to their specific commodities.

3. Your Customs Broker

As a CHB with decades of experience navigating compliance issues, our team can guide you through your compliance questions, or point you to the right party who can help.

C J’s Compliance Officer: Samya Murray, LCB, CCS

sdmurray@cjinternational.com | 410-963-3533

Contact Samya for compliance questions or to schedule a consultation — she will perform a mock audit with a compliance checklist, to help your company identify any gaps in your compliance procedures.

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