importingsnapshot

Couldn't confirm presence of Flash 8 or higher because JavaScript was disabled.Get FlashI really do have Flash installed.ul{margin-top:0px;margin-bottom:0px;list-style-type:none;padding-left:20px;}1. Import Compliance Snapshot

This compliance snapshot is provided to you by GRVR Attorneys. We won't release your information to anyone outside of our law firm (your submission will be encrypted). The snapshot we create in response to your answers is designed to help your compliance program, but this is a free service and solely informative. It is not legal advice and cannot and should not take the place of a legal opinion from an experienced trade compliance lawyer. We have a whole team of excellent lawyers. Let us know if you are interested in retaining our legal services.

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2. Classification - Unless the goods are exempted from entry, importers must classify the goods they import under the Harmonized Tariff Schedule of the United States. Tariff classification determines the amount of duty that an importer owes, whether the goods are under quota, subject to antidumping duties, or qualify for duty-savings programs. Tariff classification helps our government prepare trade statistics.
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Do you have a complete, accurate, and current classification database under the Harmonized Tariff Schedule of the United States for all the merchandise and items that your company imports into the United States?
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[ ] a. Yes. We have a classification database that we mostly or completely generated internally.

[ ] b. Yes. We have a classification database that was created and is kept current by a customs broker or other compliance professional.

[ ] c. No. We do not have such a database.

[ ] d. I do not know.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

3. If you have a customs broker or a consultant from outside the company assisting with your tariff classifications, do you independently and periodically supervise or audit the tariff classifications for accuracy?
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[ ] a. Yes.

[ ] b. No. We do not use outside consultants or brokers to help us classify our imported products.

[ ] c. No. While an outside broker or consultant helps us with tariff classification, we do not monitor or audit for accuracy.

[ ] d. I do not know.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

4. Do you have complete and accurate records, and accompanying procedures, regarding all entry documents needed to support your tariff classifications?
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[ ] a. Yes. We keep all such records internally.

[ ] b. Yes. We rely on our customs brokers or other consultant to keep all our entry records.

[ ] c. No.

[ ] d. I do not know.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

5. Special Programs: If it qualifies, an importer may (but is not required to) use a tariff classification or special trade program to avoid paying duties (and sometimes fees). The programs that allow this kind of special treatment include: The Generalized System of Preferences (GSP), Harmonized Tariff Classification 9801 and 9802, NAFTA, and other special programs.
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If you make duty saving claims under any of these special programs, do you verify that the merchandise qualifies, including creating a complete and accurate paper trail (for example, obtaining any certificates of origin or repair itemizations) of the transaction?
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[ ] a. Yes.

[ ] b. No. We do not make any such claims.

[ ] c. No. While we take advantage of one or more of these programs, we do not verify that the merchandise qualifies.

[ ] d. I do not know.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

6. Do you use or operate in a Foreign-Trade Zone?
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[ ] a. Yes.

[ ] b. No, but we are open to the possibility.

[ ] c. No.

[ ] d. I do not know.

7. Valuation: An importer must provide and report to US Customs and Border Protection the value of imported merchandise.
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In determining the value of imported merchandise, do you consider assists, packing costs, proceeds of subsequent resale, direct or indirect payments, after-the-fact adjustments, payments for purchased quota, payments for locally obtained tooling, currency rate fluctuation adjustments pegged to a contract, commissions, or royalties?
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[ ] a. Yes. We routinely appraise imported goods internally, and consider all of the above.

[ ] b. Yes. But we depend on our suppliers to provide us with the correct valuation.

[ ] c. No. We do not do this because we do not have any of these additions to our imported goods.

[ ] d. I am not sure what we do with valuation.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

8. Manufacturing assists are items such as material components, molds, equipment, tools, and dies that the importer provides to the foreign manufacturer at a reduced cost or free of charge for use in producing the imported merchandise. Design and development costs undertaken in a country outside of the United States are also assists.
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Do you have manufacturing assists?
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[ ] a. Yes. Our compliance program verifies that all assists are reflected in the value reported to CBP.

[ ] b. Yes. But there are gaps in how we report these assists to CBP.

[ ] c. No. I am sure we do not have assists.

[ ] d. I do not know.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

9. Record Keeping: Importers are required to keep or retain records on file. CBP will penalize an importer for failing this duty.

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Which of the following most accurately reflects how your company retains import records?
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[ ] a. We have a centralized record-keeping system and keep all records as required by the (a)(1)(A) list for at least 5 years.

[ ] b. Our record-keeping system is decentralized and we keep all records as required by the (a)(1)(A) list for at least 5 years.

[ ] c. We have a good record-keeping program, but I'm not sure how we long we retain records.

[ ] d. We applied for and received permission from CBP to keep our records electronically.

[ ] e. All our import records are kept by a record-keeper certified as such by CBP.

[ ] f. We depend on our customs broker to keep all our records.

[ ] g. We do not have much of a record keeping program.

[ ] h. I do not know.

[ ] i. None of the above. [if you wish to explain your answer, you may do so on the final slide].

10. Training
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Does your company provide regular (at least annual) training to all employees involved in importing merchandise?
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[ ] a. Yes.

[ ] b. No.

[ ] c. I do not know.

[ ] d. None of the above. [if you wish to explain your answer, you may do so on the final slide].

11. Please describe the type of training you provide to your import personnel. Please include delivery method (webinar, in-person, seminar, in-house training, intranet lessons), how you keep record of the training, and topics covered.

12. Country of Origin
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Which of the following best describes your company?
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[ ] a. We confirm the country of origin of every item we import.

[ ] b. We think we know the country of origin, but we do not confirm it.

[ ] c. We do not know the country of origin of our imported goods.

[ ] d. I'm not sure.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

13. Which of the following best describes your company?
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[ ] a. We make sure that our imported goods are prominently and visibly marked with the correct country of origin.

[ ] b. We mark our imported goods with the country of origin, but I'm not sure how good a job we do.

[ ] c. We do not mark our imported goods with the country of origin as we should.

[ ] d. Our imported products do not require country of origin marking.

[ ] e. I do not know what our policies and procedures are regarding this issue.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

14. Customs Broker Management
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Which of the following most accurately reflects your contract and power(s) of attorney with your customs broker(s)?
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[ ] a. We negotiated a contract and power of attorney under terms and conditions to fit our particular needs, and we limit and track the number of powers of attorneys to brokers.

[ ] b. We signed a contract and power of attorney that the customs broker provided. We do not track or limit our powers of attorney.

[ ] c. We do not have a contract with our customs broker(s).

[ ] d. I do not know.

[ ] e. We do not use customs brokers.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

15. Which of the following most accurately reflects how your company views the outside customs brokers it contracts with?
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[ ] a. Brokers are great, but we're ultimately responsible for compliance, so we check everything our brokers do.

[ ] b. If there is a problem with classification, valuation, etc., it is the customs broker's fault, not ours. We pay them to get these things right.

[ ] c. I do not know.

[ ] d. We do not use customs brokers.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

16. Emergencies
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Which of the following best describes how your company handles notices from CBP, for example, CBP Form 28 (Request for Information) or CBP Form 29 (Notice of Action)?
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[ ] a. The notice is immediately forwarded to the proper company official and calendared for possible response/action.

[ ] b. We file it in our records, but take no action.

[ ] c. No real policy. More ad hoc than anything.

[ ] d. I do not know what we do.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

17. Which of the following best describes how your company handles voluntary prior disclosures when your company violates an import law or regulation?
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[ ] a. We file prior disclosures and take the necessary steps to prevent recurrence of violations.

[ ] b. We filed prior disclosures in the past, but need to refine how we prevent violations of the kind reported in the prior disclosures.

[ ] c. We do not file prior disclosures as a matter of policy.

[ ] d. We do not file prior disclosures because we just haven't thought about it much.

[ ] e. I do not know what our policy is.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

18. If a special agent or two showed up at your company's front door with a subpoena or search warrant, which of the following best describes what your company would do?
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[ ] a. Our contingency plan or emergency compliance unit would kick in.

[ ] b. We'd have to play it by ear.

[ ] c. We haven't much thought of it, but we're not worried.

[ ] d. We haven't much of a plan, but we ARE concerned.

[ ] e. I do not know.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

19. Management
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Which of the following most accurately reflects your company?
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[ ] a. We have a business unit or department dedicated entirely to import compliance.

[ ] b. We do not have a business unit for import compliance, but we do have an import compliance director/officer.

[ ] c. We do not have a dedicated business unit, but we do have an administrative person handling our import compliance.

[ ] d. We do not have a dedicated business unit or assigned person, but deal with compliance on an ad hoc basis.

[ ] e. I do not know.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

20. Which of the following most accurately reflects your company?
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[ ] a. Management at its highest levels has clearly and widely mandated company-wide compliance with import laws.

[ ] b. Management promotes import compliance, but limited solely or only to units/groups directly involved in importing.

[ ] c. Our company is new to importing or import compliance.

[ ] d. None of the above.

[ ] e. I do not know.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

21. Do you request and obtain ruling requests (official interpretations) from US Customs and Border Protection to supplement your compliance efforts?
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[ ] a. Yes. We have ruling requests and we have procedures ensuring that we comply with those ruling requests.

[ ] b. Yes. We have ruling requests, but we do not have procedures to ensure compliance with those requests.

[ ] c. Yes. We have ruling requests, but I am not sure whether we comply with them.

[ ] d. No. We do not have ruling requests, but don't need them.

[ ] e. No. We do not have ruling requests, but I do not know why we don't have them or it is a compliance area that needs attention.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

22. Which of the following most accurately defines your foreign suppliers?
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[ ] a. We import mostly or only from a related company (parent company, sister company, joint venture partner).

[ ] b. We import mostly or mainly from companies not related to our company.

[ ] c. We import both from companies that are and are not related to our company.

[ ] d. I do knot know.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

23. Which of the following most accurately captures why you import:
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[ ] a. We mostly or only sell our imported products to companies and consumers.

[ ] b. We mostly or only use the imported goods within the company.

[ ] c. A combination of a and b.

[ ] d. I do not know.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

24. Which of the following most accurately reflects your company's written import compliance procedures?
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[ ] a. We have written procedures, including desktop procedures, that are updated periodically and that are easily accessible by all relevant employees.

[ ] b. We have written procedures, but no desktop procedures, that are updated periodically and that are easily accessible by all relevant employees.

[ ] c. We have written procedures, but they are not updated periodically or are easily accessible by all relevant employees.

[ ] d. We do not have written procedures.

[ ] e. I do not know.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

25. Which of the following reflects how your company audits its import compliance programs?
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[ ] a. We periodically audit our internal controls, including post-entry reviews.

[ ] b. We periodically audit our internal controls. The periodic audit is performed by someone within the company.

[ ] c. Our audits of our import controls are more limited than described above.

[ ] d. We do not audit our import procedures.

[ ] e. I do not know.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

26. For any audit your company performs of its import procedures, does the audit include review of post-entry procedures to confirm that all information declared to CBP is accurate?
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[ ] a. Yes.

[ ] b. No. Our audits do not do this.

[ ] c. No. We do not audit.

[ ] d. None of the above. [if you wish to explain your answer, you may do so on the final slide].

27. What is your company's status under the US Customs and Border Protections-Trade Partnership Against Terrorism, also known as C-TPAT?
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[ ] a. We are C-TPAT certified and gone through the validation process.

[ ] b. We are C-TPAT certified, but have not gone through the validation process.

[ ] c. We are not C-TPAT certified, but either are about to or we recently applied to the program.

[ ] d. We are not C-TPAT certified, but may be interested in participating.

[ ] e. We are not C-TPAT certified and are not interested in the program.

[ ] f. I do not know.

[ ] g. None of the above. [if you wish to explain your answer, you may do so on the final slide].

28. Has your company ever been the target of a Focused Assessment, Customs Audit Team (CAT) audit, or some other audit by CBP?
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[ ] a. Yes.

[ ] b. No.

[ ] c. I do not know.

[ ] d. None of the above. [if you wish to explain your answer, you may do so on the final slide].

29. Has your company been investigated by CBP?
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[ ] a. Yes.

[ ] b. No.

[ ] c. I do not know.

[ ] d. None of the above. [if you wish to explain your answer, you may do so on the final slide].

30. Which of the following best describes your role and responsibilities in regards to trade compliance for your company?
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[ ] a. I have the authority to make compliance improvements as needed, including hiring outside professionals to help.

[ ] b. I have the authority to make compliance improvements as needed, but someone else hires outside professionals.

[ ] c. I work with others to make compliance improvements and to hire outside professionals.

[ ] d. I work with others to make compliance improvements, and our company does not hire outside professionals.

[ ] e. Someone above me or in another department makes needed compliance improvements.

[ ] f. We are currently trying to figure out who is responsible for what.

[ ] g. None of the above. [if you wish to explain your answer, you may do so on the final slide].

31. Which of the following most accurately reflects your company?
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[ ] a. We have a pretty good and established import compliance program and are looking for minor tweaking.

[ ] b. We are trying to overhaul an established program.

[ ] c. We barely have a program at all, but are committed to jump starting our compliance efforts.

[ ] d. We barely have a program, and maybe want to take some tentative, modest compliance steps.

[ ] e. I don't know.

[ ] f. None of the above. [if you wish to explain your answer, you may do so on the final slide].

32. Our law firm, GRVR Attorneys, hosts seminars, webinars, and training sessions for the business community. What is your experience with our training programs?

[ ] a. We partificipate often and really like them.

[ ] b. We participated once or twice and liked the presentations.

[ ] c. We participated before, but came away thinking you really needed to improve.

[ ] d. We never participated in one of your training programs.

[ ] e. None of the above. [if you wish to explain your answer, you may do so on the final slide].

33. Which of the following best reflects your company?
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[ ] a. We have a law firm helping us with compliance and are not looking for a new firm.

[ ] b. We have a law firm helping us with compliance, but are open to possibly contracting with other law firms.

[ ] c. We do not have a law firm helping us with customs issues, and are actively looking for one.

[ ] d. We do not have a law firm helping us, but we are open to maybe hiring a firm.

[ ] e. We do not have a law firm helping us with customs, and we are not interested in hiring a law firm.

[ ] f. I do not know.

[ ] g. None of the above. [if you wish to explain your answer, you may do so on the final slide].

34. When would you like us to contact you? What time during the business day is best for you? What day of the week?

35. Here is more space if you would like to tell us anything else about your company or your import compliance program that would help us prepare a snapshot.

Thank you for your answers. We appreciate your patience as we process your trade compliance snapshot. In the meantime, here is our contact information.

GRVR Attorneys
214.720.7720
info@exportimportlaw.com

Main Business Address:

Park Place Center
Suite 300
2911 Turtle Creek Boulevard
Dallas, Texas 75219

Mailing Address:

Post Office Box 131587
Dallas, Texas 75313-1587

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