Friday, November 3, 2017

United States Customs and Border Protection (CBP) Enforcement Priorities

Peter Quinter, Shareholder
Customs & International Trade 
(305) 416-6960

Here is what I have noticed for 2017. 

This is a preview of my annual Top 10 List video next month.

1.  CBP is conducting a record number of importer audits, resulting in significant penalties.

2.  Importers from China better check twice to be absolutely sure their imported products are not subject to antidumping or countervailing duties, but if they are, to be sure it is properly declared to U.S. Customs and Border Protection (CBP) and any extra duties are paid timely to CBP.

3.  CPSC (Consumer Product Safety Commission) now has representatives at all ports of entry, and is actively selecting children's and other consumer products for compliance. There are lots of new rules applicable to toys so beware.

4.  Adulterated food and misbranded food products are a common occurrence, and FDA is using its new regulatory authority to find them, seize them, destroy them, refuse them entry into the United States, conduct recalls, and assess penalties against companies involved in the international importation.

5.  Foreign Trade Zones and customs bonded warehouses are suspected by Homeland Security Investigations of being used to smuggle everything from drugs to counterfeit products.

6.  Bureau of Industry and Security (BIS) Special Agents are conducting a record number of 'educational visits' to exporters. What you say can be used against you.

All in all, Customs and International Trade lawyers have had a very busy year, and I have not even talked about the Trump Administration disconnect with China, Iran, and Korea yet!