The first sale rule allows duty to be based on the sale of goods from the manufacturer to a middleman/vendor in qualifying multi-tiered transactions rather than the sale from the middleman/vendor to the importer. It is a highly effective method for legitimately lowering import tariffs and one that is increasingly utilized to mitigate the impact of Section 201, 232, and 301 tariffs.

Sandler, Travis & Rosenberg litigated the case that established the first sale rule under U.S. law in 1988 and in 2008 led a coalition that secured legislation affirming first sale when U.S. Customs and Border Protection threatened to discontinue it. ST&R has also developed a secure online portal for first sale clients that streamlines the implementation process; provides real-time access to project status, tasks, and timelines; and secures client data to support compliance and reliable recordkeeping.

Why Use ST&R’s First Sale Valuation Services

Cost savings: We’ve successfully implemented hundreds of first sale programs that have lowered import tariffs for our clients. 

Certainty: First sale offers a proven way to lower tariffs in an uncertain global trade environment.

Experience: Our U.S.- and Asia-based first sale professionals include former regulatory auditors and attorneys with extensive experience in valuation matters.


Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.