Issue 267, August 15, 2000
On August 10, 2000, Customs? New York Strategic Trade Center (STC) began what it calls an ?intervention? on the country of origin marking of wearing apparel. The purpose of the intervention is to address patterns of discrepancy and noncompliance found by Customs involving country of origin marking of imported wearing apparel.

The intervention will be conducted in two phases. During the first phase, select wearing apparel importers will receive an informed compliance letter and a copy of the informed compliance publication entitled "Marking Requirements for Wearing Apparel." This letter will discuss the patterns of noncompliance found nationwide by U.S. Customs. Importers will be advised to make sure that their respective transactions are free of these errors. The informed compliance letter will also request that the recipient send a copy of the letter to its foreign vendors of wearing apparel and to its brokers or filers.

Phase two will commence 120 days later. The STC will begin reviewing all quarterly discrepancy findings based on compliance measurement exams, targeted cargo exams and entry summary reviews. Importers found to have repeated discrepancies in the same categories as those outlined in the informed compliance letter will be designated for appropriate follow up action, which could include penalties.

The STC is targeting a select group of wearing apparel importers. This group is limited to: 1) all national and port accounts for this type of merchandise, 2) the remaining top 500 importers of wearing apparel and 3) all importers with a marking discrepancy based on fiscal year 1999 compliance measurement exams.

Our contributing writer, F.D. ?Rick? Van Arnam, is a Partner at the Customs and international trade law firm of Barnes, Richardson & Colburn in New York City, and can be reached via email or at (212) 725-0200.

Please note that due to the complex nature of the subject matter, Danzas AEI cannot be responsible for actions taken by the reader in reliance on the information contained herein without prior consultation with Danzas AEI.