- Anti-Corruption Compliance & Investigations
- Border Security Program: C-TPAT
- Customs & Other Agencies
- Customs Communications, Investigations & Regulatory Audits
- Duty Drawback
- Forced Labor
- Foreign Trade Zones & Other Duty Deferral Programs
- Free Trade Agreements & Other Preference Programs
- Hazardous Materials Compliance & Defense
- Import Compliance
- Product Safety
- Rules of Origin Determinations & Country of Origin Marking
- Tariff Classification
One of the most beneficial mechanisms to reduce an importer’s duty liability is First Sale Customs Valuation, also known as First Sale for Export, which allows for duty to be based on the first sale between the manufacturer and a middleman/vendor in qualifying multi-tiered transactions.
ST&R is a recognized leader in achieving First Sale duty savings for clients in the U.S. Our comprehensive program is dedicated to identifying the accurate duty-saving margins between the middleman vendor and the First Sale seller. We manage First Sale implementation through our secure online portal which streamlines the implementation process, provides real-time access to project status, tasks and timelines and secures client data to support compliance and reliable recordkeeping. In selective cases, our “cost shifting” program allows importers to generate additional duty savings beyond First Sale qualification.
Our U.S.- and Asia-based First Sale professionals include former U.S. Customs (CBP) regulatory auditors and attorneys with extensive experience in valuation matters. Our Hong Kong staff includes professionals fluent in Cantonese, Mandarin and Taiwanese, who interface directly with vendors and Asian representatives’ buying offices.
Background: What Is First Sale Customs Valuation?
First Sale Customs valuation only applies for qualifying multi-tiered transactions and must be vetted before implementation. Sandler, Travis & Rosenberg has been a leader in establishing and maintaining First Sale as a duty-savings mechanism since ST&R attorneys first litigated the case that established the first sale rule under U.S. law in 1988 (E.C. McAfee Co. v. United States, 842 F.2d 314 (Fed Cir. 1988)). When CBP threatened to discontinue First Sale in 2008, we organized and led the coalition and lobbying effort that resulted in legislation that in effect saved First Sale, and our team of valuation experts has led the charge to preserve an importer’s right to First Sale benefits ever since.
Learn More About First Sale Customs Valuation
- January 16, 2019
- The Art of the Trade Deal 2.0 – Update on Top Strategies to Avoid or Reduce Section 232 and 301 Duty IncreasesSeptember 7, 2018
- The Art of the Trade Deal - Top Five Strategies to Avoid or Reduce Section 232 and 301 Duty IncreasesJuly 11, 2018
- January 18, 2018
- January 4, 2018
- September 23, 2016
News Alerts & Advisories
- September 21, 2016
- Customs Officials Ease Back on Changes for First-Sale Rule [California Apparel News]September 18, 2014
- First Sale Rule to Remain Unchanged for Now [Sourcing Journal]September 11, 2014
- First Sale in crosshairs [American Shipper]August 17, 2014
- U.S. Customs Could Hinder Importers’ Use of First Sale Rule [Sourcing Journal]July 10, 2014
- July 9, 2014