Clearance, declarations, audits, CBAM and special regimes
This is the live thread for Wednesday's session with Anna Lindqvist. Post your questions before the webinar and we will take them in order; the thread stays open afterwards for follow-ups. Pre-submitted questions get answered first, that's the reward for showing up early.
Client has a 1986 pickup, originally titled in California, exported to Mexico in 2002 and registered there in his name ever since. He has the original US title, the export paperwork, and the current Mexican registration. He wants it back in the US and is asking me whether EPA and DOT rules even apply to something that started out American, and whether he is looking at duty on the way back in. I don't file personal vehicle entries often enough to answer this from memory, and I don't want to guess on something with his name on it.
I've got a one-time drawback claim to file (duty over $10,000 on non-conforming goods), and the broker who handled the original import doesn't do drawback at all. Everyone else I've called either wants a bigger claim than mine or only takes clients they already work with regularly. I can fill out most of the paperwork myself; it's only a handful of SKUs. Is a claim this size just not worth anyone's time, or am I looking for the wrong kind of firm? I'd rather understand that than keep getting turned down without knowing why.
Our Q2 CBAM submission used default values for two Turkish steel suppliers who won't share emissions data. The registry flagged the report because defaults are no longer accepted for those CN codes without a documented data request trail. What does an acceptable 'we tried' file actually look like, emails? formal letters? contract clauses?
A CBP bulletin, a CSMS message, started circulating that reads as though drawback (the refund on duties for goods that are later exported) is no longer available for the newest round of 301 tariffs. I went back through the executive order and the Federal Register notice that created this round of tariffs and could not find anything that mentions drawback, in either direction. I am two years into this role, so I am not confident I am reading the right documents, or reading them correctly. Has anyone confirmed whether the bulletin reflects an actual change to the underlying order, or is it possible the bulletin itself went further than what was actually enacted?
A forwarder sent us a power of attorney for a first-time importer, filled in carelessly, and became annoyed when we said we needed it executed directly by the importer of record, with photo identification and a CBP Form 5106. He kept insisting none of that was necessary. I sent him the customs guidance on validating a power of attorney, and he argued with that too. I am two years into this and I genuinely do not know where the line sits. Is direct execution plus identification the ordinary standard that everyone applies, or is my employer stricter than most? I would rather find out now than find out during an audit that we were the unreasonable ones.
One pallet, five HTS lines on a CF214 admission. The packages field will not take five separate entries against a single pallet, so I put the full count on the first line and zero on the rest, keeping quantity, value and weight per line as usual. It transmits, but it does not feel like the intended method, and I want to know before it becomes routine. Same setup, worse, at six pallets and thirty-plus HTS numbers, some finished machines, some the same machines' components shipped separately. Does the package count follow the carton, or does it split some other way once the line count gets that far past the pallet count?
Import declaration for chilled goods via Dover, rejected with CDS40045 (document code mismatch) even though the 999L waiver line looks correct. HMRC helpline suggested 'resubmit'. It failed three times. Before I raise a formal query: has anyone hit this with SPS goods since the July release?
