Issue 309, July 17, 2001
What are "best practices" for importers? A recent Customs document provided to companies within the Communications Primary Focus Industry gives over 50 examples of "best practices" relating to classification, value, quantity, special duty programs, broker and supplier oversight, internal operations and EDP operations. Among the "best practices" listed by Customs are:

	realizing it is the importer and not the broker who is ultimately responsible for customs compliance
	requiring brokers to have written authorization before changing any classifications used by the company
	establishing employee-training requirements and sponsoring in-house customs seminars
	giving engineers, buyers, and other non-Customs staff pertinent Customs training
	creating a tariff classification database for imported items and providing the database to the company's brokers
	having an annual review of the company's Customs appraisement policy
	requiring suppliers to provide invoice descriptions that are sufficient to classify an imported article

These best practices do not guarantee that a company is acting with reasonable care, but are useful for benchmarking what other importers are doing. (Editor's Note - Danzas AEI Intercontinental offers a full schedule of seminars relating to importing and exporting. To learn more, visit www.danzasaei.com/seminars.)

Finally, while not listed in the document, another best practice is to build a database that links import declarations, on an ACS entry line level, to purchasing records, on an invoice line level (i.e., a database that will show ACS entry line level 001 covered part no. 123 on invoice no. XXX, line 5). Creation of such a link gives the importer enormous benefits and control over their import operations. For example, if audited, the audit sample can be drawn from company records, rather than Customs' records. By drawing a sample from invoice lines, rather than ACS entry lines, there will be no need for multistage sampling. In addition, if the company is ever rate advanced or if the company discovers any compliance issues, it will quickly be able to quantify the impact of the issue.

Our contributing writer, Michael Roll, is an attorney at the international trade and Customs law firm of Katten, Muchin & Zavis in Chicago, and can be reached via email or at (312) 902-5200.

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.