U.S. Treatment of Remanufactured Goods at the Border

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U.S. Treatment of Remanufactured Goods at the
Border
Elif Eroglu Attorney-Advisor, Regulations and
Rulings, Office of International Trade U.S.
Customs and Border Protection
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CBP Mission

• Securing our nations borders, while facilitating
  the flow of legitimate travel and travel
• CBP protects more than 100,000 miles of shoreline
  and land border
• We operate 330 ports of entry, and process almost
  106 million cars, buses, trucks, trains, vessels
  and aircraft arriving at our borders each year
• We screen more than 28 million commercial
  shipments arriving in air and maritime cargo, and
  250 million more arriving in small parcels via
  express carriers and mail

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Growing Trade Complexity

• Global economic integration creates a challenging
  trade environment. To effectively manage this
  complexity, CBP utilizes an effective risk
  management approach

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CBP Risk Management Approaches

• Multi-Layered Approach to Risk
• Obtaining advanced information about cargo
• Using advanced targeting techniques to assess
  risk
• Fostering partnership with the private sectors
  and OGAs
• Expanding enforcement efforts earlier in the
  supply chain
• Maintaining robust inspection regimes at our
  ports of entry

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CBP Risk Management Approaches

• Priority Trade Issues (PTIs)
• CBP focuses its actions and resources around
  Priority Trade Issues (PTIs) that pose a
  significant risk to consumers, stakeholders, and
  the economy of the United States

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CBP Trade Strategy

• Goal 1 Facilitate Legitimate Trade and Ensure
  Compliance
• Ensure the compliance of the overall import
  stream and improve the speed at which legitimate
  goods are cleared into U.S. commerce
• Goal 2 Enforce Trade Laws and Collect Accurate
  Revenue
• Apply consistent enforcement actions enabled by
  risk management and targeting and collect the
  proper amount of revenue
• Goal 3 Advance National and Economic Security
• Protect consumers and the economy from harmful
  imported goods and unfair trade practices,
  advance U.S. Government security and safety
  priorities, and strengthen national trade policy
• Goal 4 Intensify Modernization of CBPs Trade
  Processes
• Build organizational capacity to streamline
  processes, strengthen workforce skills, and
  realize the benefits of modernization

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How does CBP Treat Remanufactured Goods?

• Rules
• No specific rules
• Regulations
• No specific regulations
• Cargo procedures
• No special licenses or certifications

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How does CBP Treat Remanufactured Goods?

• Document review procedures
• Classified the same
• Valued the same
• Enforcement concerns
• No specific risk determined
• No problems experienced
• Part of random sampling, but not targeted

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How does CBP Treat Remanufactured Goods?
Remanufactured merchandise would be classified as
the same type of merchandise in new condition,
and receives no special treatment from Customs
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U.S. Trade Preference Programs

• Recovered goods derived from used goods and
  utilized in the production of remanufactured
  goods are originating
• Recovered goods
• Materials in the form of individual parts that
  are the result of
• the disassembly of used goods into individual
  parts and
• cleaning, inspecting, testing, or other
  processes as necessary for improvement to sound
  working condition

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U.S. Trade Preference Programs

• Remanufactured goods
• Made from recovered goods
• Have a life expectancy and performance standards
  similar to those for new goods
• Have a factory warranty similar to what is
  offered on new goods
• Some FTAs limit coverage to certain industrial
  goods identified by specific tariff number

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U.S. Trade Preference Programs
U.S. - Korea Free Trade Agreement Article
6.22 "Recovered goods derived in the territory
of one or both of the Parties from used goods and
utilized in the territory of one or both of the
Parties in the production of remanufactured
goods" Remanufactured goods means goods
classified in Chapter 84, 85, 87, or 90, or under
heading 9402, HTSUS, that (1) Are entirely or
partially comprised of recovered goods and, (2)
Have a similar life expectancy and enjoy a
factory warranty similar to such new goods
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U.S. Trade Preference ProgramsU.S. - Korea Free
Trade Agreement Example
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