U.S.-Peru Trade Promotion Agreement to Become Effective February 1, 2009

The U.S.-Peru Trade Promotion Agreement (UPTPA) will go into effect on February 1, 2009. According to the Office of the U.S. Trade Representative, 80 percent of U.S. industrial and consumer products and more than two-thirds of current U.S. farm exports will enter Peru duty-free when the agreement takes effect. Under the agreement, Peru will enjoy permanent trade preferences that were temporary under the Andean Trade Preference Act. Additionally, Peru will be removed as a beneficiary country under the Generalized System of Preferences. In order to receive preferential treatment under the UPTPA, U.S. and Peruvian goods must qualify as originating using tariff shift rules similar to those found in NAFTA, CFTA and CAFTA-DR. Duties on some originating goods will be eliminated immediately on February 1, while others will be phased out over a 10 to 17 year period.

For more detail on the tariff shifts, RVC and other requirements, visit the USTR web site to view the final text of the UPTPA.

CBP Posts Notice of Exam for April 2009

U.S. Customs and Border Protection posted a notice to its web site announcing the April 2009 Customs Broker License Exam. The exam will be held on Monday, April 6, 2009 and applications (CBP 3124E) to take the exam must be received on or before Friday, March 6, 2009. Applicants should bring the following reference materials to the exam. Please note the appropriate editions for the HTSUS and CFR.

- Harmonized Tariff Schedule of the United States (2008 version – Supplement 1)

It is important to use this edition since questions often require the determination of the correct HTS number, duty rate and applicability of Free Trade Agreements, all of which may change slightly from year to year.

- Title 19, Code of Federal Regulations (revised as of April 1, 2008 Parts Parts 0 to140, 141 to 199 and 200 to End) (no supplements)

- Customs and Trade Automated Interface Requirements (CATAIR)

• Appendix B - Valid Codes
• Appendix D - Metric Conversion
• Appendix E - Valid Entry Numbers
• Appendix G - Common Errors
• Appendix H - Census Warning Messages
• Appendix L - Drawback Errors
• Glossary of Terms

- Instructions for Preparation of CBP Form 7501 (8-30-2005)

-C-TPAT - Minimum Security Criteria for Customs Brokers (3-20-2007)

-Submission Changes for Supplemental Information Letters and Post Entry Amendments

-Remote Location Filing Eligibility Requirements

- Directives

• 3510-004, Monetary Guidelines for Setting Bond Amounts
• Amendment to 3510-004 for Certain Merchandise Subject to Antidumping/Countervailing Duty Cases
• 3550-055, Instructions for Deriving Manufacturer/Shipper Identification Code
• 3550-067, Entry Summary Acceptance and Rejection Policy
• 3550-079A, Ultimate Consignee at time of Entry or Release
• 3560-001A, Census Interface-Processing Procedures
• 5610-002A, Standard Guidelines for the Input of Names and Addresses Into Automated Commercial System (ACS) Files

Note: CBP added the C-TPAT Minimum Security Criteria for Customs Brokers (3-20-2007) to the list of reference materials for the April 2008 exam and asked five questions related to that document. Be sure to read the C-TPAT document thoroughly and review the questions from the April Exam!

It’s time to get ready for the next Customs Broker Exam! Click HERE for a complete list of our study plans and products designed to help you study and pass the exam! As always, the only way to guarantee that you receive the correct editions prior to the Notice of Exam posting is the get the Required Testing Material package through Boskage. Don’t forget to visit the Boskage Trade News Blog for additional for import/export news updates, articles about specific trade topics and helpful posts related the Customs Broker Exam!

Importer Security Filing Events Scheduled

U.S. Customs and Border Protection "CBP" has posted a list of trade outreach events to be hosted at various locations in the U.S. These events are designed to provide the trade community with an opportunity to learn more about the new Importer Security Filing and Additional Carrier Requirements (ISF or ”10+2”) interim final rule. These events are intended to give the importing and filing community a basic understanding of how to comply with the new requirements. Space is limited so please use the links below to pre-register.


The following cities are scheduled for January 2009:

• Oakland, CA - Wednesday January 14, 2009( Oakland, CA Registration )


• Baltimore, MD - Thursday January 22, 2009( Baltimore, MD Registration )


• Philadelphia, PA - Friday January 23,2009( Philadelphia, PA Registration )


• Charleston, SC - Wednesday January 28, 2009( Charleston, SC Registration )


• Savannah, GA - Thursday January 29, 2009( Savannah, GA Registration )
  

Note: Specific event information with location details and further instructions will be emailed to registrants after completion of the on-line registration process.

Check the blog or the CBP website for scheduling of these events in the following cities.

• Houston, TX


• Boston, MA


• Miami/Port Everglades, FL


• Long Beach, CA


• Chicago, IL


• Norfolk, VA

Customs Broker Triennial Status Report Due

In accordance with the provisions of 19 CFR 111.30(d), every licensed broker must file a status report and pay a corresponding fee every three years. The report and fee of $100 must be submitted to CBP during February 2009. There is no required format for this report; however, CBP provided a sample. The elements of the report contained in 19 CFR 111.30(d) may be provided on a sheet of paper and submitted to Customs along with the money order or check for the corresponding fee. Again, the attached sample report is only a suggested format and its use is not mandatory. A report that is filed during the month of February 2009 is considered timely filed. CBP offices will begin accepting status reports and the corresponding fee on January 2, 2009. Any license for which no report and fee is filed is subject to suspension by operation of law.

Each individually licensed broker must state whether or not he/she still meets the applicable requirements of 19 CFR 111.11 and 111.19 and has not engaged in any conduct that could constitute grounds for suspension or revocation under Section 111.53. Individuals are considered to be “actively engaged in customs business” when they are currently or have recently transacted customs business on behalf of others as a sole proprietor OR when they are employed by a licensed customs broker who is currently or has recently transacted customs business on behalf of others. Those who work for another broker and are not directly involved in any activities which fall under the scope of the definition of “customs business” may report that they are “NOT actively engaged in customs business.”

All valid licenses for which no report has been submitted will be suspended by operation of law on March 1, 2009. In cases like these, the port director will transmit a notice of the suspension to the broker during the month of March 2009 at the last known address reflected in CBP records. During the sixty-day period beginning on the date of the aforementioned suspension notice, the broker may submit a status report and fees to the appropriate port director. If this occurs, the license will be reinstated. Unfortunately, failure to submit a status report and the corresponding fees to CBP during the sixty-day period will result in the license being revoked. Such licenses are revoked by operation of law without prejudice to the filing of a new application for a license. You worked hard for that license and you don’t want to take the broker’s exam again, so arrange to file your report today!

Increase in Dept. of Commerce Penalties

On December 11, 2008, the Department of Commerce (DOC) issued a final rule in the Federal Register adjusting certain civil monetary penalties under their jurisdiction. These adjustments were made to adjust for inflation and only apply to violations occurring after the effective date of December 11, 2008. Some of the penalties adjusted by this final rule include the following:

BIS Fastener Quality Act – Old $27,500 to New $32,500
International Emergency Economic Powers Act violations –Old $50,000 to New $250,000

Economics & Statistics Administration
International Investment and Trade in Services Act violations (failure to furnish information) - Old $27,500 to New $32,500

International Trade Administration
U.S.-Canada FTA Protective Order violations - Old $120,000 to New $130,000

"10+2" Importer Security Filing Interim Final Rule Published

Just two days before Thanksgiving, U.S. Customs and Border Protection gave the trade something to be thankful for by publishing the interim final rule for the new Importer Security Filing in the Federal Register. The importer security filing requirements will go into effect 60 Jan. 25, 2009, with enforcement to begin one year later. Due to concerns about the costs of collecting the huge amount of data, reporting requirements and the changes necessary to adjust to the new rules, CBP will show restraint in enforcing the rule for 12 months after implementation so long as importers are making satisfactory progress toward compliance and demonstrating a good faith effort to comply.

The "10+2" rule requires importers to submit 10 pieces of data 24 hours prior to loading at a foreign port, and ocean carriers to provide two pieces of information about the status of containers under their control.

Although the interim final rule includes some changes to the rule originally proposed by CBP, such as allowing some flexibility on the filing deadlines for two of the 10 importer elements, most of the other requirements remain unchanged.

Changes

• CBP is allowing flexibility in what importers report in six data elements: manufacturer, consolidator, stuffing location, country of origin, tariff commodity number, and the “ship to” party.

• The container stuffing location and consolidator's name should be provided as early as possible, but will be accepted up until the 24-hour pre-loading deadline.

• Breakbulk cargo is no longer included in vessel stow plans.

• Compliance penalties were changed from the value of the merchandise to $5,000 per violation.

• Provisions were included for creating an importer security filing bond.


Basic Requirements

Importers, or their agents, must transmit an Importer Security Filing to CBP, for cargo other than foreign cargo remaining on board (FROB), no later than 24 hours before cargo is laden aboard a vessel destined to the United States.

The party required to submit the Importer Security Filing is the party causing the goods to enter the limits of a port in the United States. The ISF Importer may designate an authorized agent to file the required data on the importer's behalf. A party can act as an authorized agent for purposes of filing the Importer Security Filing if that party obtains access to ABI or AMS.

The Importer Security Filing is required for each shipment, at the lowest bill of lading level, including the house bill of lading, if applicable.

The required ISF data must be transmitted via a CBP-approved electronic data interchange system. Required importer data elements must be filed through the Automated Broker Interface; carriers will file by way of the Automated Manifest System.

The 10 data elements required from importers and two from carriers are those that appeared in the proposed rule. The interim final rule requires Importer Security Filing (ISF) importers to provide the following eight data elements no later than 24 hours before the cargo is laden aboard a vessel destined to the United States:

1. Seller.
2. Buyer.
3. Importer of record number/FTZ applicant identification number.
4. Consignee number(s).
5. Manufacturer (or supplier).
6. Ship to party.
7. Country of origin.
8. Harmonized Tariff Schedule of the United States (HTSUS) number.
The ISF also includes two data elements that must be submitted "as early as possible," but no later than 24 hours prior to the ship's arrival at a U.S. port.
9. Container stuffing location.
10. Consolidator (stuffer).

Implementing a program of this magnitude will likely undergo some changes, so be sure to check the CBP web site for various helpful documents related to the security filing such as fact sheets, FAQ’s and other announcements.

Lacey Act Implementation Delayed

The statutory deadline for compliance with the declaration requirement under the Lacey Act amendments is December 15, 2008. To address the concern of both the trade and federal agencies, the USDA has proposed phased in enforcement of the Lacey Act starting around April 1, 2009. (April Fools Day!) Some importers may not be required to comply until July. The following is a proposed timeline for the implementation and enforcement.

December 15, 2008 - Paper declaration form available and accepted. No prosecution for failure to complete the form from December to end of March unless false information submitted.


April 1, 2008 – Enforcement of declaration requirement for HTS chapters 6 and 44. Electronic collection of required declaration available.


July 1, 2008 – Enforcement of declaration requirement for additional HTS chapters – 47, 48, 92, 94


Sept 2009 – Phased-in enforcement for additional HTS chapters 12, 13, 14, 45, 46, 66, 82, 93, 95, 96, and 97.

In case you’ve been busy resolving other trade issues and haven’t paid much attention to this one, remember that the Lacey Act requires submission of a declaration for a wide variety products such as live plants, lumber, paper, products containing plant material such as furniture, tools, sporting goods, printed matter, musical instruments and textiles. Importers will be required to report the species of plant/wood and country of origin. Check out the USDA web site for more information about the Lacey Act.

Check Out November Issue of AES Newsletter

Overwhelmed by the new AES requirements? Take time out to read some helpful information in the November edition of the AES Newsletter. This edition contains some useful information on the following topics:

• Impact of New Foreign Trade Regulations (FTR).


• Penalties and filing deadlines for various modes of transportation.


• AES Downtime Policy.


• Explanation of the differences between suppression and cancellation of AES filings.


• Clarification on Routed Export Transactions and responsibilities.


• Information about monthly AES compliance reports sent to filers.
  

Visit the AES web site for additional resources.

DHS Transition Team Announced

President-elect Barack Obama has named the Transition Agency Review Teams that are charged with completing a thorough review of key departments, agencies and commissions of the United States government. Reporting to Sara Sewell, Rand Beers was appointed to lead the Homeland Security team and will be assisted by Clark Ervin. Beers and Ervin will be responsible for reviewing DHS budgets, personnel and policies. It is predicted that the new administration will act cautiously with respect to Homeland Security issues.

Current DHS Secretary Michael Chertoff will leave the agency at the end of the year. Prospective candidates for Secretary of Homeland Security in the Obama administration: include:

· William J. Bratton - Chief, Los Angeles Police Department
· Jane Harman - Member, U.S. House of Representatives (D-Calif.)
· Raymond Kelly -New York City police commissioner
· Janet Napolitano - Governor of Arizona (D)

The next secretary inherits the daunting tasks of securing the nation's borders against illegal immigration, preventing the next terrorist attack on America and leading the federal response to natural disasters. In addition, he or she will be responsible for 200,000 employees and over 80 congressional oversight committees and subcommittees.

CBP Commissioner Basham is also preparing to leave office; however, no names of potential candidates have been published. Stay tuned, it’s likely names for the new commissioner will start circulating soon!

Exam Letters From CBP

Since so many of you have been asking about the letters from CBP concerning the exam, we went straight to the source at CBP. Here’s what our contact at CBP had to say:


“The answer sheet and answer key were sent by the vendor that does the scoring. The official letter is sent by HQ. The letters from HQ didn’t go out as quickly as the answer sheets, thus the confusion. The letters are on their way.”


So, for those of you who are wondering about the letters, just be patient a little longer and you’ll receive one in the mail soon!


Make the Boskage Trade News your favorite place to read about new developments concerning the Customs Broker Exam as well as new developments and useful information concerning international trade!

CBE Appeal Checklist

If you plan to appeal your CBP Exam score, it is important to follow CBP’s appeal requirements. CBP will reject the appeal if it:

• is incomplete, is untimely, or is in the wrong format


• includes any arguments written by another person


• does not provide supporting arguments


• argues for an answer the applicant did not select


• contests an incomplete erasure or insufficient marking on the applicant’s answer sheet
  

CBP will provide to the examinee written notice of the decision on the appeal. If the CBP decision on the appeal affirms the result of the examination, the examinee may request review of the decision on the appeal by writing to the Secretary of Homeland Security, or his designee, within 60 calendar days after the date of the notice of that decision. 19 CFR 111.13(f)

Save yourself some time and expense by submitting your very best arguments the first time. To help you submit an appeal that complies with CBP requirements, we’ve created the CBE Appeal Checklist. Be sure to review each item and place a check mark next to the individual requirements.

CBP Posts October Exam Results

For all of you who have been patiently (or not so patiently) waiting on the results of the October 2008 Customs Broker Exam, the results are posted on the CBP web site. Results will be mailed and should be in your mailboxes in the next 7 to 10 days. Some ports have been calling people, so you may receive a phone call.

For those of you who purchased the Boskage Study Plans that included the detailed exam commentary, we’ll be completing that information and posting it soon. Look for upcoming articles on protesting questions on the exam.

CBP Announces ISA-Product Safety Program

If you are a current ISA participant thinking about ways to improve compliance, now might be a good time to consider the Importer Self-Assessment Product Safety Pilot. In addition to receiving time on the agenda at the U.S. Customs and Border Protection Trade Symposium October 29 – 31, CBP announced in the Federal Register that they would begin a trial program to expand the Importer Self-Assessment Program to include product safety. The trial is designed to encourage companies to maintain a high-level of compliance with product safety laws and standards.

The ISA-Product Safety pilot will be conducted by CBP, CPSC and volunteer importers. Existing ISA members can apply for the product safety program and the two agencies will select a limited number of the applicants to participate. In order to participate in ISA–PS, an importer must:

· Be an active member in ISA and comply with all ISA requirements and obligations.
· Complete an ISA–PS/CPSC Questionnaire and sign an ISA–PS/CPSC Addendum.
· Agree to comply with all laws and regulations administered by CBP, as well as the CPSC
· Maintain an internal control system that ensures the integrity of product safety.
· Notify CBP of any major organizational changes that may affect the importer’s product safety controls.
· Submit an annual written notification to CBP that sets forth the importer’s ISA–PS point of contact and acknowledges that the importer continues to meet the requirements of ISA–PS.

Companies selected for the pilot program will be expected to follow a set of best practices compiled by the government. Through domestic site visits, CBP and the CPSC will verify that companies have adequate procedures and processes in place to ensure product safety throughout the supply chain.

As an incentive, the CPSC will offer increased benefits to companies that join the program. Some of these benefits include:
· Assigning a product-specific point of contact that can assist in providing product codes of recalled products for inclusion on customs entries.
· Training on product safety compliance, internal controls and agency audit procedures.
· Allowing companies to extend ISA coverage to multiple business units.
· Fewer product safety tests on goods.
· Granting "front of the line" privileges at CPSC laboratories to ISA-PS participants when product safety testing is necessary.
· Allowing products to be destroyed instead of requesting redelivery of faulty goods to CBP.
· Automatic enrollment in CPSC's Fast-Track Product Safety Recall Program.

The pilot program will be reviewed after two years to determine whether it should become permanent.

CBP Issues Frequently Asked Questions on AES Filings

U.S. Customs and Border Protection (CBP) has published two documents containing answers to frequently asked questions about AES. The first document contains general questions and answers about AES such as costs and hardware and software requirements. The second document contains specific process-oriented questions, and is designed to assist the trade community in understanding the expectations of CBP concerning the advance electronic cargo information rules for export shipments.



Click on the following links to review each FAQ.
General FAQ
Specific FTR FAQ

USITC Introduces HTS Online Reference Tool

The U.S. International Trade Commission (USITC) introduced the development of the new HTS Online Reference Tool. Managed by the USITC, the new tool will be a single source of information for importers, brokers, carriers and the government.

The HTS Online Reference Tool will provide:

• Complete legal text and notes;
• The most current U.S. tariff rates;
• Interactive access and searches;
• Direct links to classification rulings;
• Quick searches by word, word combinations or HTS number;
• Direct links to footnotes;

The system will provide access to the most current rulings. Users will be able to jump directly from a specific HTS item to the Customs Ruling Online Search System (CROSS) for determinations on product classification for that HTS item.

The tool also provides thesaurus capability and the ability to use synonyms, such as “doll” instead of “toys”. Using XML software, the ITC will be able to quickly update the HTS for changes such as Free Trade Agreements and duty rate reductions.

Look for this fantastic new tool in the first quarter of 2009.

ATPA and GSP Extended

On October 16, 2008, President Bush signed H.R. 7222 which extends benefits under the Generalized System of Preferences (GSP) for one year until December 31, 2009. The Andean Trade Preferences Act (ATPA) was extended to December 31, 2009 for Columbia and Peru and to June 30, 2009 for Bolivia and Ecuador.

Preliminary Answers for the Oct. 2008 Exam

As many people sit on pins and needles waiting to see the answers posted for the most recent Customs Broker’s Exam, our very own Wizard has taken the exam and provided a list of possible answers and related regulations where the answers were found.

We invite you to post your answers, explanations, arguments and other comments. Obviously, Boskage Commerce Publications cannot guarantee the accuracy of these answers since CBP has the one and only answer key, but the Wizard has an excellent record of achieving a score of better than 90%.

Click HERE to view a copy of the Wizard’s answers for the October 2008 Exam!

Additional commentary on the exam will be available to our students soon.

Exam Answers Coming Today

Keep refreshing, the Wizard will have answers today, along with possible protests by the end of the day!

Customs Broker Exam Study Tip 12: CBP Directives

For many years, the Customs Brokers Exam only required the use of the HTSUS and the CBP Regulations; however, in 2004, CBP expanded its scope of materials to include Customs Directives and other reference materials. These materials are important because they provide guidance on activities that brokers perform that aren’t included in the regulations. Since their inclusion, these resources have comprised 7.5% of the total questions on the exam. Because of the number of resources, it’s difficult to predict specific areas for testing. The best thing to do is to study all of it. We’ve provided the key highlights for the four most frequently tested supplemental resources.

1. Instructions for Preparation of CBP Form 7501

Although most entry summaries are completed electronically, it’s important to have a good understanding of the information contained on this document. By reading these instructions, you could complete a CBP 7501 by hand without the assistance of a computer. You should keep this document handy and review all blocks because it has been one of the most frequently tested supplemental resources since the implementation of the new CBP 7501 format in September 2005. Become very familiar with each block number, so you can easily reference it. Block 2 (Entry Type Code) and Block 31 (Net Quantity) are easy targets!



2. CD 3510-004 - Monetary Guidelines for Setting Bond Amounts

The purpose of the bond is to protect the revenue and ensure compliance. The amount of a bond is calculated using information on the bond application, the criteria in Part 113 of the CBP Regulations and the guidelines in this directive. This directive provides standardized guidelines for computed the bond amounts for all types of bonds. For the exam, it’s important to know how to calculate single entry and continuous bonds.

The first type of bond is the Activity 1, Importer or Broker Continuous Bond. The minimum amount of a bond in this category is $50,000.

For importers paying zero to $1,000,000 in duties and taxes, the bond should be computed as 10% of the duties and taxes paid for the previous calendar year and issued in increments of $10,000.

For importers paying over $1,000,000 in duties and taxes, the bond should be computed as 10% of the duties and taxes paid for the previous calendar year and issued in $100,000 increments.

The next type of bond is the Activity 1, Importer or Broker Single Transaction Bond. This bond is valid for one shipment and is computed in an amount not less than the total entered value of the merchandise plus all duties, taxes and fees unless the merchandise is subject to other government agency requirements such as the FDA, and all merchandise subject to quota and/or visa requirements. In these situations, the bond will be computed in an amount of at least three times the total entered value of the shipment. In addition, the district director may set the single transaction bond amount at 10 percent of the total entered value for unconditionally free merchandise, which is not subject to the previously mentioned categories.


3. CD 3550-055 - Instructions for Deriving Manufacturer/Shipper Identification

Questions involving the Manufacturer’s ID code should be some of the easiest to answer. Not only does this directive provide instructions on how to construct the code, but the information is also included in the CBP Form 7501 Instructions. Just memorize the rules for deriving the Manufacturer's ID number.

This code is commonly referred to as the MID or Manufacturer Identification Code. This technique is also known as keylining. On the broker’s exam from October 2005, a question required knowledge of the term keylining.

Customs requires the formation of a code from the name and address of the manufacturer.
The MID contains five components that are added together without spaces to create the code. The code can be up to 15 characters in length. The five components consist of the following information:

· Two letter abbreviation for the country of origin
· First three letters of the first name of the manufacturer
· First three letters of the second name of the manufacturer
· First four digits of the street address, and
· First three letters of the city name.

There are some general rules to consider.


· Ignore all punctuation
· Ignore single character initials. and
· Ignore the words “a”, “an”, “and’, “of”, and “the”.


4. 3550-067 - Entry Summary Acceptance and Rejection

Customs Directive 3550-067 provides guidelines for uniform acceptance and rejection of entry summaries. Five major areas of interest in this directive include the following:

· Collections Processing – Rejections
· Acceptance Review and Summary Processing
· Processing of Rejected Entry Summaries
· Time Limit
· Rejection Effect on Entry Summary Filing Time

This information is a little more complicated to grasp, so read each of the major areas and highlight key information.

Although we didn’t cover all of the directives and supplemental materials, they are not any less important. Remember the advice from the beginning of the article - the best thing to do is to study all of it.

We welcome your comments on these suggestions and encourage you to add your own ideas to this forum so that other students studying for the exam can benefit from your experiences. Check the Boskage Trade News regularly for other useful news for international trade professionals! As soon as the Wizard obtains a copy of the test and has time to work out some preliminary answers, we’ll post them here for you to review and comment on!

Customs Broker Exam Study Tip 11: Free Trade Agreements

With the increase of free trade agreements between the U.S. and other countries, the number of questions on the CBE related to these agreements has increased. In fact, “Trade Agreements” often has its very own section of questions on the exam. Free Trade Agreements (FTA's) are international agreements made between two or more nations that relate to common trade or service issues. FTA’s reduce or eliminate all tariffs and other restrictions on substantially all the trade in goods between its member countries based on country of origin.

The information needed to answer questions about FTA’s is likely to be found in one of three places: (1) the General Notes of the HTSUS, (2) Chapters 98 an 99 of the HTSUS and (3) 19 CFR Part 10. Memorize the titles of these General Notes and skim the text to become familiar with the topics covered in each. In your review of the programs, concentrate on the basic requirements such as tariff shift, de minimis and RVC requirements. Each program has different requirements regarding allowance of the special duty treatment, and some of these programs are subject to change. Most of these programs have very detailed requirements that must be met in order to claim the duty-free status. Additionally, these programs are often difficult to understand and some have limited use in daily practice. Try not to be too overwhelmed when encountering these problems. If they appear too difficult, move and come back to them later.

Don’t overlook important terminology. Be sure to know the definitions for each of the following:

· Accumulation
· Direct Cost of Processing
· De Minimis
· Imported Directly
· Transshipment
· Regional Value Content RVC
· Tariff Shift
· Substantial Transformation

To view a list of the FTAs, the references to the HTSUS General Notes, SPI and CFR references, click HERE.

We welcome your comments on these suggestions and encourage you to add your own ideas to this forum so that other students studying for the exam can benefit from your experiences. Check the Boskage Trade News regularly for more helpful hints on studying for the Customs Broker Exam and other useful news for international trade professionals!