“The tariff engineering” is in the popularity where companies are trying to deliver duties

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Colorful display of all star sneakers in the shoe store, Manhattan, New York.

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Will it be disturbed if your coat is officially classified as a wind pilot or a rain coat, or your shoes as a shower? Although companies are interested, because the classifications under a favorite category can help them pay lower tariff prices.

While US President Donald Trump imposes duties on friends and enemies alike, manufacturers are increasingly rethinking their products and resorting to “tariff engineering” to bear fewer duties.

The customs tariff engineering – a practice preceding Trump – includes changing the materials of a component, changing its dimensions or works so that the final products can be justified to suit them differently “Coordinated system code,” Legal experts said.

Although most of the new definitions that were added during the second period of Trump on a large scale, the United States government has it Current exemptions for some productsCommercial lawyers indicated that leaving the doors open to companies to benefit through the engineering of the tariffs.

After Trump revealed the overwhelming “mutual” definitions in April, many manufacturers abroad moved to steel and aluminum elements in their final products to qualify a 25 % lower duty under Section 232David Safar, a partner at Chicago Lawyer Barnes, Richardson and Kulporn said.

However, things changed rapidly in June when Trump definitions of all products and derivatives of solid aluminum to 50 %, with the exception of those in the United Kingdom “now after the duties have been reversed, we see companies now remove those elements and charge them separately again.”

Identification is one of the few things that you can do to try to obtain it properly and reduce your duty responsibility.

John Foot

Customs lawyer, Kelly Dry Warne

“There is nothing illegal in nature or even undesirable about taking advantage of the strategic design options that lead to the creation of different products that are subject to the classification of different tariffs and customs duties,” said John Foot, a customs lawyer in Kelly Dre and Warne in Washington, DC, said.

There is finished 5000 different products classification codes The American customs authority is used during the evaluation of definitions. These customs tariff classifications have been determined during contracts of negotiations between governments and industrial bodies, and they often vary according to the product category.

“It planned” to work with external experts to develop and implement effective (introductory) mitigation strategies, including tariff and delay engineering. “

Travel trailer stands at Winnebago Industries Inc. At Motor SportLand RV in Salt Lake City, Utah, United States, on Monday, April 6, 2020.

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Anil Salman, head of economic security at the Institute of Policy Research in Islamabad, described the law as “a smart art for articulated customs”, as importers and manufacturers who modify the products “enough” to qualify for less duties.

Smart plays

“I was talking to someone recently and they were offering me a jacket’s chest pin,” said Kelly Dre, Warne Warren. Foot said that the pin, which was placed on a person’s suit, said it includes a “festive design” with pieces of cubic zirconia in the back.

The cube Zacconia insert helped the company that makes these nails a 14 % tariff, as this element no longer falls under the category of festive articles but was classified as jewelry, after that, I learned Foot.

“The value that was attributed to the cubic zirconia was large enough (and) was a relatively easy change in manufacturing,” said Foot.

The practice of customs tariff engineering can be returned to 1882, when the imported sugar is with sugar molasses to avoid higher duties imposed on lighter sugar. in Ruling on a teacherThe Supreme Court ruled this action completely: “As long as the goods are truly invoices, and frankly with customs officers to examine them, there is no fraud.”

Since then, companies, large and small, have continued to play chess with the American tariff classification system, with the implementation of many of the names of living families successfully to provide the costs of customs tariffs.

For example, Columbia SportsWear was never shy of using customs tariff engineering. “I have a full team of people who work with designers, developers, merchants and customs, and to ensure that during the design process we think about the impact of customs tariffs.” Market through Trump’s first period.

Among its modifications, the company added small pockets below the waist on women’s shirts, allowing them to be exempt from higher duties below American customs rules.

Likewise, the shoe maker Conversation adds a mysterious fabric To the sole of sneakers, all the stars, instead of the full model shoes, to be classified as sediments instead of sports shoes, which helps it significantly reduce the customs tariff.

Snuggies, a delicate blanket with sleeves mainly imported from China, has averaged to half of the costs of customs tariffs by winning a lawsuit in 2017 classified as a blanket, not an element of clothing.

Central Valle, New York – November 17: Colombia Sports Clothes Company is attached to its store at Woodbury Combris Premium Shopping on November 17, 2019 in Central Valle, New York.

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Andrew Wilson, a supply chain expert at the Consulting Consulting Company at the Consulting Company, said that the sectors of consumer, good clothes, clothes, and shoes can find that it is relatively easy to implement customs tariff engineering.

Wilson said that the most advanced sectors and “great organization” such as “cars, space, electronics and medical devices” said.

“You may look at 12 to 24 months of testing, issuing certificates and verifying health in order to accomplish this,” Wilson added, as it requires intense cooperation through departments, including design, engineering and legal team.

The rules of interpretation

How to use companies

“The article must be” commercial fact “when importing. The danger is that customs (May) find that the changes are” fraud or manufacture “, (that case) may be rejected by the customs tariff engineering,” said Forgue.

“In some cases, it does not change the change of some things about the basic personal product of what is good,” said Derek Scarpro, the founder of global logistical communications. “If you add something to a shopping cart, it is still a shopping cart,” he added.

Customs and American border surveillance developed the so -called The “binding government” system Where companies can obtain official decisions on products categories and HTS code before importing.

Adam Liz, a lawyer for the law firm Harris Slangeki, who helped customers prepare these ruling messages, described it as a “companies to obtain an official blessing for CBP” before shipment.

For companies, even “small percentage savings can be meaningful”, as LEES stated, where charging can be large.



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