Important Notice to Textile Importers

Issue 496, November 11, 2005

The requirement of the Textile Certificate by Customs and Border and Protection (CBP) for imports of textiles and textile articles has been abandoned effective November 5, 2005. As the Textile Certificate is no longer required, the replacement control process to inform CBP of the country of origin (defined as the country in which the subject goods have had "origin-conferring operations" performed) is the electronic transmission of the Manufacturer’s Identification number (MID) by the broker for each article imported. This requirement creates a new set of burdens for importers and brokers and is subject to the specific Rules of Origin for each specific textile material or article of apparel.

A grace period until November 18, 2005 has been granted after which time enforcement will begin.
While this is a positive step towards paper reduction and administrative effort on the part of shippers, importers brokers and CBP, however, it does, in fact, create an even greater liability and risk for you.

What should you do?

	Immediately implement purchase order requirements to your vendors to reflect the MID number of the actual origin-conferring party (as defined in CFR19 102.21 or 102.22) of each good on their commercial invoice. Instructions for the encryption of a MID number can be found as set forth in the new Appendix to Part 102 of the Customs Regulations, including the use of the correct two-letter International Organization for Standardization (ISO) code for the country of origin. Remember that the origin-conferring manufacturer may not be the same party who actually sells or ships the merchandise to you.
	Immediately contact all your vendors of textile materials in writing to instruct them to show this MID number clearly on their commercial invoice documents for compliance and reasonable care reasons.
	Immediately inform your broker as to the MID numbers you wish to have electronically transmitted to Customs on your behalf.
	Be cognizant of a vendor's change in suppliers that may affect the MID documented and transmitted to CBP on your behalf. Hold them accountable for making the necessary revisions in the MID reflected on their invoices and advise you accordingly as changes are made.

What are the risks?

	The transmission of an accurate MID for the origin-conferring party is an importer of record compliance and reasonable care responsibility. Inaccurate data may lead to unnecessary inquiries or related penalties.
	Contradictory countries of export and countries of origin without confirming MID numbers may delay the release and entry of your import cargo.
	Your broker will transmit the MID of the shipper unless otherwise instructed by the shipper on their invoice with a corresponding line by line MID or by information you have provided the broker.
	All transmissions are the result of a communication from the importer of record, and accountability is 100% in the hands of the importer.

This change in the international trade environment for textile goods and articles require an examination of your supply chain to ensure that all parties are aware of their responsibility to avoid delays and unnecessary costs to the importer of record.