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Produce Importers Report CBP Valuation Inquiries

Tuesday, October 25, 2016
Sandler, Travis & Rosenberg Trade Report

A growing number of importers of fruits and vegetables are receiving from U.S. Customs and Border Protection letters requesting specific information about the relationships between buyer and seller and the nature of the transactions resulting in the shipments. There is some concern that this effort could presage a tougher CBP enforcement effort, possibly including audits, focusing on the valuation of produce imports.

In these letters CBP is seeking to ascertain (1) whether the shipments are purchased directly from the seller or exported to the U.S. on consignment, (2) which sellers are related parties (if any), (3) which producers or suppliers sell directly to the importer and which export to the importer on consignment, and (4) if the shipment is on consignment, the value declared at the time of entry, whether the company files reconciliation entries and, if not, the actions the importer will take if the amount remitted to its suppliers is greater or less than the value declared at the time of entry. The letters also refer importers to CBP’s informed compliance publications on customs value and reasonable care and CBP’s valuation encyclopedia.

Fruit or vegetable importers receiving these letters are encouraged to contact ST&R for assistance. For more information, please contact Len Rosenberg at (305) 894-1002.

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