Customs

  • CBP Responds to Letter on ITDS Implementation

    On January 20th, the United States Fashion Industry Association (USFIA) joined a coalition letter to Secretary of Homeland Security Jeh Johnson reiterating the importance of the President’s Executive Order on Trade Facilitation and support for a commercially meaningful single window by the 2016 deadline. The letter was signed by 31 associations. On March 15th, Deputy Secretary Alejandro Mayorka, Chair of the Border Interagency Executive Committee (BIEC) responded, noting “on-time delivery of the ITDS by the December 2016 deadline remains a top DHS priority. Today, over half of ITDS technical capabilities have been successfully deployed and U.S. Customs & Border Protection is on track to complete the remaining core components by July 1, 2015.” He also discussed the next steps, including testing system capabilities in real-work environments, and gradually increasing the volume of goods being processed through the system, as well as ensuring all parties are ready for ACE. The letter is available here.

  • CBP to Host Section 337 Enforcement Seminar

    U.S. Customs and Border Protection (CBP) will host a Section 337 Enforcement Seminar on September 14-15, 2021. The seminar will include discussions on preparing for an Exclusion Order, Exclusion Order Enforcement, and the Administrative Rulings process. Learn more about the seminar here.

  • Center of Excellence & Expertise (CEE) for the Industry

    U.S. Customs & Border Protection (CBP) has been developing and implementing Centers of Excellence & Expertise (CEEs) for all U.S. industries. The goals of the CEEs are:

    1. To serve as a single point of processing for businesses enrolled in CBP’s trusted shipper programs, such as Customs-Trade Partnership Against Terrorism (C-TPAT) and Importer Self-Assessment (ISA);
    2. To increase industry-based knowledge to segment risk, develop trade facilitation strategies, and enhance enforcement; and,
    3. To serve as a resource for the broader trade community and CBP’s U.S. government partners.

    The CEEs continue CBP efforts to increase uniformity of practices across ports of entry, facilitate the timely resolution of trade compliance issues nationwide, and further strengthen critical agency knowledge on key industry practices. They represent CBP’s expanded focus on “Trade in the 21st Century,” transforming customs procedures to align with modern business. By having the CEEs focus on industry-specific issues, CBP is able to provide tailored support to unique trading environments.

    The CEE for Apparel, Footwear, & Textiles officially opened for applications on June 3, 2013, with six initial companies, including some United States Fashion Industry Association (formerly USA-ITA) member companies. Dora Murphy, Director of the CEE for AFT, has said that CBP will continue to add companies to the CEE as they increase capacity and staff.

    The CEE for Apparel, Footwear, & Textiles has been a top priority for the United States Fashion Industry Association (USFIA), formerly the United States Association of Importers of Textiles & Apparel (USA-ITA), and our members. USFIA welcomes the opening of it and inclusion of some USFIA member companies. We look forward to continuing to engage in dialogue with CBP, and particularly the CEE staff, to ensure that this program works for our industry.

    USA-ITA (now USFIA) was part of the Industry Working Group for the CEE, which provided recommendations to CBP on how the CEE should work, where it should be located, etc. USA-ITA members participated in an industry survey to provide specific recommendations, which were compiled in a White Paper for CBP. In addition, USA-ITA/USFIA regularly meets with CBP officials, including Director of the CEE for AFT Dora Murphy, to discuss updates and our views. More information on our industry and our CEE is available here.

    USA-ITA (now USFIA) hosted one of the first public presentations by the CEE’s Director Dora Murphy, during our West Coast Seminar on February 21, 2013, in San Francisco. USFIA welcomed her again to our Summer Seminar on June 19, 2013, and annual conference on November 6, 2013, in New York City. USFIA remains active in promoting additional webinars and other information by Ms. Murphy and looks forward to continuing to work with her and her team in the future.

  • Dialogue with the CEE

    USA-ITA (now USFIA) hosted one of the first public presentations by the CEE’s Director Dora Murphy, during our West Coast Seminar on February 21, 2013, in San Francisco. USFIA welcomed her again to our Summer Seminar on June 19, 2013, and annual conference on November 6, 2013, in New York City. USFIA remains active in promoting additional webinars and other information by Ms. Murphy and looks forward to continuing to work with her and her team in the future.

  • Informal Entry

    In 2011, U.S. Customs & Border Protection (CBP) proposed an increase in the informal entry limit from $2,000 to $2,500. The current $2,000 limit was established in 1998, but due to inflation, the real value today is less and leads to an administrative burden on importers. Once the changes are adapted, only products covered by certain temporary modifications or agricultural products subject to a safeguard measure will be excluded from the normal informal entry limit.

    Most importantly the CBP proposal will eliminate the prohibition from using informal entry for textile and apparel shipments. This is a substantial improvement for companies that import textile and apparel products.  

    In a Federal Register Notice published on October 28, 2011, CBP requested comments on the proposed increase:

    Section 662 of the Customs Modernization provisions of the North American Free Trade Agreement Implementation Act raised the statutory limit by which the Secretary of the Treasury is authorized to prescribe rules and regulations for the declaration and entry of, among other things, importer merchandise when the aggregate value of the shipment does not exceed an amount specified but not greater than $2,500. The current limit of $2000 was established in 1998 and while that dollar amount has been unchanged, inflation over the intervening years has reduced the value of that amount in real terms. Consequently, CBP proposes to raise the current informal entry amount to its maximum statutory limit in response to inflation that has occurred and thereby to reduce the administrative burden on importers and other entry filers. Moreover, CBP proposes to remove the language requiring formal entry for certain articles, because with the elimination of absolute quotas under the Agreement on Textiles and Clothing, CBP no longer needs to require formal entries for these articles. This document also makes non-substantive editorial and nomenclature changes.

    USFIA Position

    The United States Fashion Industry Association (USFIA), formerly the United States Association of Importers of Textiles & Apparel (USA-ITA), continues to actively work to eliminate any “special” protection for textile and apparel products. USA-ITA asked U.S. Customs and Border Protection (CBP) to eliminate the restriction on the use of “informal entry” for textile and apparel products in 2005 when the World Trade Organization (WTO) quota system was eliminated, and in 2009, when the China textile safeguards expired. We strongly support action by CBP to facilitate trade and eliminate unnecessary barriers.

    Advocacy

    On December 19, 2011, USA-ITA (now USFIA) submitted comments to CBP in favor of the proposed change. In the comments, USA-ITA President Julia K. Hughes said,

    CBP proposes to increase the informal entry limit to $2,500 and, more importantly, to eliminate the current restrictions on the use of the informal entry procedure.

    At present, the informal entry limit for textiles and apparel is $250. This different treatment was justified because of the comprehensive absolute quota system that applied to that class of merchandise. The quota system has been dismantled for some time and there is no longer a justification for requiring formal entry for textile and apparel shipments valued at less than the normal informal entry limit.

    The proposed changes will result in modest savings in Merchandise Processing Fees and a decrease in processing times for smaller shipments. USA-ITA anticipates that the changes will permit textile and apparel import specialist teams to concentrate on higher level enforcement priorities by eliminating the requirement to process the lower value shipments.

    USA-ITA and its members strongly support the proposed changes. Indeed, they have long urged that the changes be made.

    For more information on CBP’s efforts to simplify the entry process, read this article from the October 2011 OFF THE CUFF member newsletter by Mary Jo Muoio, Senior Vice President at OHL Trade Services.

  • USFIA Files Comments on CBP’s Proposed Rulemaking on Electronic Notices of Liquidation

    On November 14, 2016, USFIA submitted comments on U.S. Customs & Border Protection’s proposed adoption of an electronic notice of liquidation. 81 Federal Register 71019 (October 14, 2016). USFIA supports the change in procedure, with a few comments/suggestions. The comments are available here.

  • USFIA Files Comments on Importer Identity

    The United States Fashion Industry Association (USFIA) has submitted comments in response to the proposed rulings by U.S. Customs and Border Protection requiring customs brokers to collect certain information from importers to enable the customs brokers to verify the identity of importers, including nonresident importers. In the comments, USFIA requests several revisions to the proposed rulings, including that the new regulations apply to all customs brokers relationships and that the final regulation should recognize that many importers belong to CBP programs that require vetting by CBP itself. The comments also ask CBP to reconsider specific requirements that are unnecessarily burdensome and could take away from targeted enforcement issues. The full comments are available here.  

  • USFIA Files Comments on Women’s Shirts with Partial Openings and no Means of Closure

    The United States Fashion Industry Association (USFIA) has filed comments on the proposed modification of three ruling letters and a proposed revocation of treatment relating to the classification of women’s knit shirts with a partial opening and no means of closure. The full comments are available here. 

  • USFIA Joins ITDS Coalition Letter

    On January 20, 2015, the United States Fashion Industry Association (USFIA) joined a coalition letter to Secretary of Homeland Security Jeh Johnson reiterating the importance of the President’s Executive Order on Trade Facilitation and our support for the Administration to develop a commercially meaningful single window by the 2016 deadline. The letter was signed by 31 associations, and the Departments of Treasury and Commerce, USTR, the White House National Security Council, and key congressional committees were copied. The letter is available here.

  • USFIA Joins Letter on Customs Reauthorization Legislation

    On May 12th, the United States Fashion Industry Association (USFIA) joined a coalition letter to the House Ways & Means Committee leadership expressing support for H.R. 1907, the Trade Facilitation & Trade Enforcement Act of 2015, or Customs Reauthorization. The letter notes that the Senate version, S. 1015, “raises several concerns because the legislation includes provisions that have not been adequately vetted or debated, are inconsistent with the United States’ international obligations, or would unnecessarily increase the bureaucracy of trade enforcement without an increase in effectiveness. Proposals included in the Senate bill are not a balanced approach to enforcement.” In particular, the letter calls out the Senate bill’s ENFORCE language, which “would burden U.S. Customs and Border Protection with a new and time-consuming administrative process,” as well as the “Leveling the Playing Field Act,” which “would amend U.S. trade remedy laws in ways that are inconsistent with U.S. international obligations under the WTO rules and would lower the standards for injury determinations.” The letter is available here.  While the Senate did pass its version of the bill, the Obama Administration issued a statement noting that it has concerns with some of the provisions, as well.

  • USFIA Joins Multi-Industry Letter on WCO Electronic Transmissions & WTO Moratorium

    On November 26, 2018, the United States Fashion Industry Association (USFIA) joined a multi-industry association letter to the U.S. Department of Homeland Security (DHS), U.S. Customs & Border Protection (CBP), U.S. Treasury, and the Office of the U.S. Trade Representative (USTR) urging the Administration to block the World Customs Organization’s plan to implement a customs duty moratorium on electronic transmissions. Led by the United States Council for International Business, the letter says the action “is contrary to the long-standing agreement by World Trade Organization (WTO) members not to apply customs duties to cross-border electronic transmissions and prejudices ongoing discussions at the WTO and the Organization for Economic Cooperation and Development (OECD). This action will harm U.S. goods and services exporters of all sizes in nearly every sector and threaten American jobs.” The letter is available here.

  • USFIA Speaks at CBP Trade Symposium in Atlanta

    USFIA President Julia Hughes spoke at the U.S. Customs & Border Protection Trade Symposium in Atlanta. She spoke about the negative impact of tariffs on companies and consumers, and the importance of global value chains.

  • USFIA Submits Comments to CBP on ICP on Apparel Terminology

    U.S. Customs & Border Protection (CBP) is updating its Informed Compliance Publication (ICP) “Classification: Apparel Terminology under the HTSUS.” The Apparel, Footwear, & Textile Center of Excellence & Expertise (CEE) asked the United States Fashion Industry Association (USFIA) to provide feedback on what to include in the revised ICP publication, which is intended to be an aid for importers when determining the appropriate HTSUS classifications for apparel. USFIA’s Customs Counsel John Pellegrini and the Customs Committee worked to develop these comments in an effort to make the ICP a better resource. If you would like to see our comments, please let us know.

  • USFIA Submits Recommendations to CBP on Simplified Entry Process

    On May 19th, the United States Fashion Industry Association (USFIA) submitted recommendations to U.S. Customs & Border Protection (CBP) on the Simplified Entry Process Phase II: Post-Release. Several of our members are participating in CBP’s Simplified Entry Working Group to ensure that the processes work well for importers in the industry. If you’d like to see the comments or have any questions, please let us know.