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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 nation’s 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 StrategyGoal 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 CBP’s 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
Fuel pump completely
disassembled
Cleaning and testing of fuel valve
Specified processing
(surface machining)
Used fuel pump of unknown origin
Recovered fuel valve used to produce
remanufactured good (fuel pump)
Remanufactured fuel pump has similar performance standards/ similar warranty as new pumps
Recovered fuel valve treated as originating for determining
whether remanufacturedfuel pump qualifies under
FTA
Recovered good (fuel valve)