CBP’s ramped-up enforcement could mean an unexpected increase in inspections of shipments to determine place of origin. Knowing how to prepare can make all the difference between delayed and on time. What are best practices needed for importers to demonstrate substantial transformation? What are new, emerging Country of Origin compliance concerns? This highly anticipated workshop will delve into critically important updates, best practices and Country of Origin pitfalls to avoid.

Country of Origin Rules: Hypothetical Scenario Planning and Practical Applications

• A practical understanding of procurement waivers
• Buy America requirements in government subsidies (IRA and CHIPS)
• Content versus origin: Which one applies?
• New, emerging compliance concerns: Changing suppliers, not knowing which program applies, training procurement staff
• 232 tariff origin rules
• Types of origin rules, non-preferential and preferential rules
  • Applying the appropriate rules of origin for different tariff determinations
  • Where Substantial Transformation Occurs or Simple Assembly
  • Applying special tariffs: Tariff shifting
  • Binding ruling requirements
  • Free Trade Agreements (e.g., USMCA) rules
• Ensuring compliance with country-specific labeling and marking requirements to avoid penalties and facilitate smooth customs clearance
• Landed cost-calculations
• How to eliminate duties through origin changes (232, 301, etc.)
• Working with your supplier to get the origin information you need
• Responding to CBP enforcement
• CF 28s/29s and origin verifications
  • Enforcement trends around origin issues
  • Documents and analysis needed to support origin claims
  • Penalty risks and mitigation
  • CBP rulings, legal opinions, and recent court cases