About The Webinar

The watch provisions within the Harmonized Tariff Schedule are among the most challenging due to the multiple breakouts requiring importers to classify and appraise at a component as opposed to a product level. In many cases, U.S. Customs and Border Protection has questioned and challenged the entry declarations of unsuspecting watch importers, which can result in liability for years of back duties and even penalties. This webinar will examine how to best address CBP’s watch inquiries and audits and to identify opportunities to reduce duty payments.

Key Topics

  • Classification: Finding favorable watch construction provisions to avoid China retaliatory or other higher duties
  • Value apportionment: Advocating for component appraisement based on your documentation and data instead of third-party data
  • Compliance: Establishing reasonable care to avoid retroactive duties and penalties
  • Duty savings: Leveraging first sale, trade preferences, and other programs
  • Marking and origin: Using the substantial transformation test to your advantage
  • Trademarks: Meeting the elusive Swiss certification standard

Please note we do not accept payment via American Express.


Lenny P. Feldman

Managing Partner, Operating Committee

LENNY FELDMAN is a Managing Partner, Operating Committee with Sandler, Travis & Rosenberg, P.A., resident in the Miami office. He previously co-chaired the twenty-member Customs and Border Protection’s Commercial Customs Operations Advisory Committee, providing strategic recommendations directly to CBP, Homeland Security and Treasury executives on issues such as forced labor, intellectual property rights, e-commerce policy, trade partnership programs, enforcement and facilitation mechanisms, and regulatory reform. He currently serves as General Counsel and Customs Counsel to the National Customs Brokers & Forwarders Association of America (NCBFAA).


Sherri R. Moslowitz


Sherri Moslowitz is an auditor for Sandler, Travis & Rosenberg, P.A., resident in the Miami office. She is directly involved with the coordination and conduct of quick response importer audits, risk analysis and survey assessments (RASA), and focused assessment reviews performed by CBP as well as the preparation and submission of prior disclosures. She also assists clients in matters involving valuation (e.g., related party transfer pricing issues, entry reconciliation programs, and first sale transactions), classification, foreign-trade zone compliance, duty preferences and free trade agreements, and other customs-related compliance issues. She began her career as an auditor with the U.S. Customs Service’s New York Regulatory Audit Division and later served as an assistant controller with a manufacturing and import company.



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