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CBP Proposes Two Amendments To Broker Recordkeeping Requirements

On March 23, 2010, Customs and Border Protection issued a notice of proposed rulemaking wherein the agency proposes to amend certain of the Regulation’s recordkeeping requirements. First, the proposed rulemaking would allow a broker to store his or her records at any location within the United States, so long as the recordkeeping contract identified in the broker’s permit application makes […]

CBP Proposes To Eliminate The Mailing Of Liquidation Courtesy Notices

CBP’s Office of Regulations and Rulings, in a rulemaking notice of March 15, 2010, has proposed to amend the Code of Federal Regulations to discontinue the longstanding practice of mailing courtesy notices of liquidation to importers of record whose entries are filed by ABI. CBP has invited the public to comment upon its proposal. CBP’s proposed move to eliminate the […]

FMC Votes To Exempt NVOCCs From Publishing Rates

On February 18, 2010, the Federal Maritime Commission voted to approve a proposed rulemaking that would exempt non-vessel-operating common carriers (NVOCCs) from the longstanding requirement that they publish tariff rates. This move was motivated by the FMC’s desire to free NVOCCs from the substantial costs of publishing tariffs, thus saving jobs. The move may result in hundreds of thousands of […]

Goodbye COGSA, Hello Rotterdam Rules

By passing the Carriage of Goods by Sea Act of 1936 (COGSA), the United States adopted as domestic legislation the Hague Rules, which govern liability for loss in ocean carriage. At that time, ocean cargo was transported largely by barrel and crate, and bills of lading covered cargo from port to port. Today, cargo is containerized and may travel long […]

The First Sale Rule: Could It Lead To Duty Savings For You?

Some readers may be aware that Customs, through a proposed rulemaking, attempted to abolish the first sale rule in 2008. The first sale rule is a method of determining transaction value, or the price paid or payable, for valuation and appraisement purposes. The rule provides that a U.S. importer may base the valuation of an imported product that was the […]

The Department of Commerce’s Bureau of Industry and Security Updates Its Freight Forwarder Guidance

The Department of Commerce’s Bureau of Industry and Security (BIS) recently posted new export control guidance for freight forwarders on its website. BIS enforces the Export Administration Regulations, which regulate the conduct of both shippers and trade intermediaries and, among other things, prohibits the unlicensed export of controlled items to certain destinations. BIS has brought administrative enforcement actions against large […]