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The purpose of this memorandum is to inform Customs and Border Protection (CBP) Field Offices and all interested parties of a grace period that will be granted to the Trade to assist in the 2007 Harmonized Tariff Schedule of the United States (HTSUS) conversion.

The World Customs Organization (WCO) amends the Harmonized System, at the six-digit level, every four to six years. The recommended changes for 2007 are substantial. The chapters most affected are the machinery chapters.

The Trade has advised CBP that, depending on the complexity and size of their import and export operations, reclassifying the products affected by the 2007 changes, along with the subsequent updating of their databases would take longer than the customary 15-day implementation period.

With the help of CBP, the Office of the United States Trade Representative, the Trade, and Congress, legislation was passed on December 9, 2006 to allow a minimum of 30 days after the Presidential proclamation is published in the Federal Register to implement the WCO changes to the 2007 HTSUS.

Since the Presidential proclamation was published in the Federal Register on January 4, 2007, the WCO 2007 HTSUS amendments will go into effect on February 3, 2007. CBP will allow the Trade an additional 17 days to implement the WCO changes. This 17-day grace period, in addition to the 30-day implementation time frame, will give the Trade more than the requested 45 days to reclassify products and update internal databases.

The grace period will facilitate the transition to the 2007 HTS by allowing adequate time to address CBP actions such as the rejection of misclassified entries and will help prevent the assessment of penalties under Title 19, United States Code, Sections 1592 and 1621 for negligence or non-egregious errors. Filers will be responsible for substantiating any additional time needed within the grace period for the late filing of entries and for making post-entry corrections. The 17-day grace period will begin on February 3, 2007 and will end at the close of business on Tuesday, February 20, 2007. Entries filed on or after February 21, 2007 will be made with the appropriate WCO HTSUS changes.

Are you looking for ways in increase your compliance rating with Customs? Have you thought about Direct-filing your imports? CBP is urging importers to gain control of their importing business. Will you be prepared with CBP starts cracking down on Compliance?

Meet the TRG Direct import direct-filing experts in New York City for the American Association of Exporters and Importers, June 1 - 3, 2008 and receive first hand information on how filing your own imports may help you increase your compliance!

Click here for details
Grace Period for the Implementation of the 2007 Harmonized Tariff Schedule of the United States

TRG Direct to present Direct-Filing Demonstrations in NYC!

The Office of Trade Policy and Programs is issuing a blanket authorization for Immediate Delivery (ID) procedures for merchandise to be released on or after January 22, 2007 and until February 2, 2007, in accordance with 19 CFR 142.21(h). The authorization is offered to filers who may want to take advantage of the Harmonized Tariff Schedule changes, which take effect on or after February 3, 2007.

This blanket authorization does not apply to absolute quota merchandise and merchandise moved under an immediate transportation entry (type 61). Tariff rate quota merchandise previously authorized for ID release under 19 CFR 142.21(e) may still be released under ID; however, the entry summary shall be presented within the time specified in 19 CFR 142.23, or within the quota period, whichever expires first.

In those instances where the paper CBP 3461/CBP 3461(ALT) is used as the entry document and importers wish to elect ID, a line must be drawn through the word “ENTRY” on the document. ABI entry transmissions, including the “paperless” provisional message, will establish the desired entry date by using the estimated entry date in the summary transmission (“EI” transmission). This will identify the change from “Entry” to “Immediate Delivery” and will allow filers to elect a date of entry in order to take advantage of tariff changes or special programs. Under ID procedures, the Entry/Entry Summary must be filed within 10 working days after release. This blanket authority extends to shipments released January 22, 2007 through February 2, 2007 only.

There will be no grace period allowed for the purpose of timely filing ID entry summaries.

April 8th, 2008

January 5th, 2007
Immediate Delivery Procedures for 2007 Harmonized Tariff Schedule of the United States
January 5th, 2007

April 1st, 2008
TRG Direct Highlighted in American Shipper Article
Kulisch, Eric. “Broker Bypass” American Shipper April 2008: 41-42

TRG Direct enables small businesses to self-file customs entries.

A few ambitious importers prepare and file customs entries on their own, but for most of them the complexity of the cargo volumes needed to justify the extra technology and staff aren’t worth the headache.
     But a new product on the market intends to make it easier for the do-it-yourself filer, especially small to medium enterprises that have lacked the expertise and systems to bring this function in-house.
     The web-based system called, TRG Direct, gives importers the ability to gain control of entry clearings and save thousands in outsourcing fees normally paid to customs brokers.
     “It’s like Turbo Tax for customs entries,” said Michael Laden, a partner in supply chain security and customs compliance consulting firm Trade Innovations.

Click here to read more.
Trade Risk Guaranty (TRG) Brokerage Services LLC is a licensed insurance agency, having agency agreements with Hanover Insurance Company of Worcester, Massachusetts and Great American Insurance Company of Cincinnati, Ohio, both of which are insurance companies approved by the Department of the U.S. Treasury to issue U.S. Customs bonds.
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