This week the Consumer Product Safety Commission voted to approve a test program to assess the electronic filing of certificates of compliance at entry in coordination with U.S. Customs and Border Protection. With the idea of better coordination among partner government agencies to facilitate electronic data collection and sharing of import data, the CPSC endorsed
Kelley Drye
California Enforces Transparency in Supply Chains Act
The Attorney General of California has recently sent letters to more than 1,700 companies notifying them that the State is enforcing the California Transparency in Supply Chains Act, which became effective in 2012. The Act requires large retailers and manufacturers doing business in California to disclose “conspicuously” on its websites “efforts to eradicate slavery and…
Are Third Party Compliance Tests Dutiable Upon Entry into U.S.?
In a recently released headquarters ruling, Customs and Border Protection (“CBP”) addressed the issue of the dutiability of payments for compliance testing. The scenario is as follows: The importer purchases merchandise from a foreign seller and imports them into the U.S. The merchandise undergoes various product compliance tests outside of the U.S. Sometimes the importer…