We have a USMCA entry that will not accept the forced-labour exclusion. I have tried it under 9903.05.93 and again under 9903.05.86, and neither one goes through. The filing comes back rejected without telling me anything useful about why.
Meanwhile the box is sitting, and the demurrage clock does not care which subheading turns out to be the right one. So before I start paying storage on a question of nomenclature: is this a real classification problem at my end, or is the system refusing a combination that is actually legitimate?
If anyone has got this exclusion to transmit on a USMCA entry recently, I would like to hear how the line was built rather than which code you used.
I had a rejection that looked like this a few months ago, and I never really understood why it cleared in the end, so I am following this closely.
The one thing I would check before anything else is what the line is landing on underneath the exclusion. When ours started refusing, the exclusion was not the problem at all: the base heading had been changed under us and nobody told us; it simply began rejecting one day.
Has your base heading moved recently?
I cannot speak to how a United States filing behaves, so please take this as context rather than as an answer.
The shape of the problem is familiar, however. When our declarations began rejecting perfectly valid combinations after a customs systems release here, the fault was never in the classification. It was in the validation rules that shipped with the release, and no amount of re-reading the legal text would ever have found it. It was resolved by raising it formally with the authority, not by changing the entry.
If the people who maintain your filing software believe the combination is permitted, escalate it as a defect and keep the correspondence. That record is what protects you if the entry later liquidates against you.
It is not one line. That is your whole problem.
The exclusion does not stand on the entry by itself. It needs the additional code alongside it, sequenced so the system can read which code qualifies which. Build it as a parent and child on the same line instead of as two separate lines and it will go.
Ask your ABI rep to confirm the sequence your particular software expects, because it is not the same order everywhere. But stop re-testing the subheading. Both of the ones you tried are probably fine.
