Fluent Essays

The answers can be found in the readings, and the links in the attached files. I want you to take your time and utilize the resources available to you for this these questions. Answer in complete sentences unless a question directs you to give a one or two-word answer. Complete the questions and upload your document. Why do we restrict imports?What are 5 ways we restrict imports?What are the objectives of the WTO?What are the two ways import tariffs are levied?What was the average tariff rate (in 2009) of the US? China? Brazil?The current administration argues we should have higher tariffs in the US to protect our own industries. What is an argument for and an argument against this idea? What is the difference between a Free Trade Area and a Customs Union? Which does NAFTA fall under?What are the two systems the US uses to classifies products?What is Chapter 9 in the HTS?Name 3 countries that qualify for special treatment under the generalized system of preferences (code A) – hint: found in the General Notes.What is the HTS for tennis shoes valued at $10/pair?What would the tariff be for 100 pairs coming from?ChinaJordanCubaWhat are 6 agencies that regulate exports?Where are trade regulations published?Which regulations are governed and published by the Department of Commerce?What does ITAR do?There are 14 “reasons for control” under the BIS regulations. What do the following reasons stand forCCMTRSWhat does the ECCN stand for?What is the ECCN for Fiber Optic Cables?What are the Reasons for Control? Do they apply to shipments to Germany? Jordon? ( You will need the country chart for this part)What are the license exceptions?What is the IC/DV procedure and when is it used?What supporting documents may be required for an export license application?Which countries issue an import certificate as a supporting document when required by the BIS?According to 15 CFR 748.9 – under “content of support documents” – what are the 2 requirements? The answers can be found in the readings, and the links in the attached files. I want you to take your time and utilize the resources available to you for this these questions. Answer in complete sent Overview of Export Regulation Our two primary objectives in this particular segment are to help you:   Achieve a general understanding of U.S. export laws and regulations in the broader context of world trade, and what most nations typically do; Become aware of all the USG agencies that regulate exports, and particularly with the functions and responsibilities of those with the greatest operational impact on U.S. exports: Bureau of Industry and Security U.S. Department of Commerce International Trade Management Division, Bureau of the Census U.S. Directorate of Defense Trade Controls Department of State U.S. Bureau of Customs and Border Protection This section is also designed as a foundation for our subsequent coverage on:   US Exports Subject to Controls, Licensing—Covers the determination whether a contemplated export requires an export license or is subject to other export controls, restrictions or reporting requirements (other than an SED).  Export Clearance (Requirements & Procedures at Time of Export)—Provides in-depth coverage of export responsibilities and operational procedures at the time of actual export, including the requirement for a U.S. shippers export declaration (SED), the various forms this may take, and numerous specific information and processing issues using both the paper form and automated (AES) procedures. Other US Export Requirements/Procedures - Covers operational procedures for cargo exported under various types of CBP control (i.e., cargo under bond) and an overview of goods subject to state laws affecting their exportation. Forwarder Responsibility for Export Compliance —Provides freight forwarders and other transportation intermediaries with practical tips and recommended procedures to help assure export compliance despite intense operational pressure to move cargo. Coverage includes how to identify and deal with suspicious exporters and how to respond to government inquiries, investigations and enforcement actions. The USC and CFR There are a variety of U.S. laws and federal agency publications that communicate prohibitions, restrictions and procedural requirements that apply to the export of goods and services, from the United States. This body of law and regulation is published in two very extensive sets of documents known as the USC and the CFR. The U.S. Congress passes legislation (bills) which, upon signature by the President become law. The provisions of each law revise or are added to the published body of U.S. law known as the United States Code (USC). The Congress is responsible for publishing the USC The United States Code (abbreviated USC) is the legislated law of the United States, consolidated and codified by subject matter into 50 titles. The Office of the Law Revision Counsel of the U.S. House of Representatives prepares and publishes the United States Code. The USC does not include:   Regulations issued by executive branch agencies and independent agencies needed to implement the USC Decisions of the Federal courts Treaties Laws enacted by state or local governments Implementation and enforcement of the law, as documented in the USC, is the responsibility of a designated Executive Branch agency of government, or in a few cases independent federal agencies such as the FMC (Federal Maritime Commission). In order to implement law, the responsible federal agency must issue or revise its regulations so as to translate the requirements of the law into regulatory policy, procedures, clarifications, etc., so that those who must comply with law (the regulated parties) have practical guidelines and procedures to follow. These regulations are published in the Code of Federal Regulations  The CFR is divided into 50 titles that align on the USC titles that such agency regulations implement. Each title is divided into chapters, which generally align on the federal agencies responsible for areas of regulation, and usually bear the name of the issuing agency. Each chapter is further subdivided into parts that cover specific regulatory areas. Large parts may be subdivided into subparts. All parts are organized in sections, and most CFR citations consist of only the title number and section to the needed level of detail. For example, 15 CFR 30.1(a), Title 15 being Commerce, Section 30 being the Foreign Trade Regulations, and 30.1(a) being the first segment of these regulations. Changes to the CFR must be published in the Federal Register before they can take effect, beginning with a notice of proposed regulations followed by a public comment period, and then concluding with publication of final regulations with a subsequent effective date, usually 90 days following final publication. If you take the time to read the USC citation on which particular CFR sections are based, which are footnoted throughout the CFR, you will often see that a paragraph from the USC translates into a page or more of implementing regulations, and often in multiple different sections of an agencys regulations, and sometimes in the regulations of more than one agency. Why they are important to you The United States actively promotes most exports to all but a very few countries. However, there are certain products and countries for which exports are prohibited or severely restricted, and a growing number of persons, companies and organizations that are subject to sanctions by various agencies which effectively bar any commerce or exchange of funds, whether domestic or international. Exporters, freight forwarders and indeed any U.S person are subject to the export administration regulations and all other U.S. laws and regulations affecting exports. Transportation intermediaries are additionally subject to direct licensing and regulation by the industry specific agencies such as the Federal Maritime Commission. If this myriad of regulations is not understood and fully complied with, violations will occur which may result in significant fines, loss of export privileges and even criminal prosecution. As you will see in the Export violations on the BIS website, exporters and forwarders (including some familiar names) have, in fact, been cited and paid significant fines for export violations. A few exporters and forwarders have also served significant prison terms for export violations. Thus, it is important that every person responsible for deciding on or arranging a U.S. export be properly trained. Many violations, particularly on the part of forwarders, consist of acting with knowledge that an export violation is about to occur, and proceeding to process the export anyway.  I recommend you browse through both the USC and CFR in order to have a general idea of how they are structured. For example, you will see that USC Title 19, captioned Customs Duties, provides the legal authority and direction for CFR Title 19, also captioned Customs Duties. Similarly, USC Title 22, Foreign Relations and Intercourse provides the legal authority and direction for CFR Title 22, Foreign Relations. Within the USC Title Sections, you will see Sub-parts which encompass U.S. legislation that has been signed into law by the President, updated as needed based on subsequent legislation. The corresponding CFR titles represent the specific administration and enforcement rules by the executive branch or independent federal agency(s) responsible for implementation of the laws within their purview. Interpreting the USC is often challenging, requiring both an understanding of what is obvious from the language therein, as well as the legislative history and how appellate court decisions may have influenced application of the law. This is the domain of the legal profession (attorneys.) Understanding and applying the CFRs represents somewhat less of a challenge because these are written to be understood by regulated parties, an audience much wider than attorneys. Publications The following are key U.S. government publications (CFRs which play a major role in controlling and processing U.S. exports. You will find these refer to, quoted and linked to throughout our coverage of U.S. export requirements.   Export Administration Regulations (EAR) - these consist of 15 CFR 730-774. The EAR is published by the BIS, an agency under the US Department of Commerce (DOC), and serves as the basis for export controls administered by the U.S. Department of Commerce—that is, what can be freely exported vs. what requires an Export License.  These regulations also direct exporters to controls administered by other federal agencies based on the type of product (e.g., military items, nuclear fuel and power generating equipment) and/or based on the party or country of destination.Information about BIS, the EAR and U.S. export controls is available at www.bis.doc.gov/ (Links to an external site.) (Links to an external site.)Links to an external site. International Traffic in Arms Regulation– Also referred to as the ITAR, these consist of 22 CFR 120-128. The ITAR is published by the U.S Directorate of Defense Trade Controls (DDTC), under the State Department, and controls the export of military items, as defined by the U.S. Munitions List (USML).Information about the DDTC, ITAR and U.S. export controls of military items is available at www.pmdtc.org/ (Links to an external site.) (Links to an external site.)Links to an external site. Foreign Assets Control Regulations - Also referred to as FACR, these consist of 31 CFR parts 500-590. These address a variety of measures to restrict business with and follow the funds and other financial assets of persons, organizations and countries which the U.S. has sanctions in place against. These sanctions and export controls are administered by the U.S Office of Foreign Assets Control (OFAC). Foreign Trade Regulations - Also referred to as the FTR, they are listed in 15 CFR 30. These regulations establish the requirement for exporters to report most exports to the USG via transmitting Electronic Export Information (EEI) through the Automated Export System (AES). The FTR is published by the Foreign Trade Division of the Bureau of Census. The FTR is primarily concerned with the gathering of U.S. trade statistics which is a Census responsibility. However, EEI is also used by CBP, BIS and other agencies for export control enforcement purposes.Information about the FTR and AES systems is available at www.census.gov/foreign-trade/www/ (Links to an external site.) (Links to an external site.)Links to an external site. Schedule B - From the last module, this publication provides the reporting classification codes that the Bureau of Census uses to gather and report U.S. export trade statistics. The Schedule B utilizes the Harmonized Tariff System (HTS) for the first six digits of the reporting code, then adds 4 U.S.-only digits similar to the HTSUS, which may also be used for EEI (export declaration) purposes for most, but not all, products. Customs Regulations - These are contained in CFR Title 19,  captioned Customs Duties. While most of these regulations address the importation of goods into the U.S., 19 CFR 192, captioned Export Control, addresses CBP responsibilities over goods being exported and operation of the AES system. These are the CFRs that together have the most encompassing effect on U.S. exports, but they are by no means all the regulations which may affect particular exports. Other agencies that regulate specialized types of products may also regulate the export of such products. All CFRs may be accessed on line at the GPO Access website, eCFR. (Links to an external site.) (Links to an external site.)Links to an external site. Regulations by specific agencies may also be available on the agencys website. The EAR, ITAR, FTR, Schedule B and other applicable U.S. regulations contain significant information not included here. Direct referral to these publications is required for their proper understanding, especially when seeking information with respect to actual export transactions and situations. Specific Reasons for Export Controls   Specific Reasons for Control The Commerce Control List (CCL) (15 CFR 774, Supplement 1) identifies a specific reason for control. Per 15 CFR 738.2(d), the reasons for control are:   AT - Anti-Terrorism CB - Chemical & Biological Weapons CC - Crime Control CW - Chemical Weapons Convention EI - Encryption Items FC - Firearms Convention MT - Missile Technology NS -  National Security NP - Nuclear Nonproliferation RS - Regional Stability SS - Short Supply UN - United Nations Embargo SI - Significant Items SL -  Surreptitious Listening Items controlled within a particular Export Control Classification Number (ECCN) may be regulated for more than one reason. Explanation of each reason for control is found in the EAR, under 15 CFR 742.  All exports under the jurisdiction of the BIS are controlled for one or more of these reasons, based on the high-level control objectives. (national security, foreign policy, nonproliferation and short supply). By keeping the above reasons for control in mind, plus the specific mission of other U.S. agencies with respect to exports,  all parties to a U.S. export (U.S. exporter,  U.S principal party of interest (USPPI), foreign principal part of interest (FPPI) and agent/freight forwarder should have sufficient insight to recognize shipments which are subject to export restrictions for which an export license may be required. A forwarder should also be familiar with EAR, 15 CFR 732 Supplement 3 (Links to an external site.) (Links to an external site.)Links to an external site., Know Your Customer Guidance. Although this is directed toward the exporter more than the freight forwarder the same step-by-step approach and red flags apply. In addition, there is more specific guidance in Freight Forwarder Guidance. (Links to an external site.) (Links to an external site.)Links to an external site. The answers can be found in the readings, and the links in the attached files. I want you to take your time and utilize the resources available to you for this these questions. Answer in complete sent Along with the pages contained in this module, make sure you read through these links (printing can be helpful so you can use as a resource): https://www.ecfr.gov/cgi-bin/text-idx?mc=true&node=se15.2.734_13&rgn=div8#b/2 https://www.ecfr.gov/cgi-bin/text-idx?mc=true&node=se15.2.736_12&rgn=div8 CCL country chart https://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=2a578d2f4eb9cabb6487e2cc8137d665&rgn=div9&view=text&node=15:2.1.3.4.24.0.1.5.27&idno=15 The CCL The CCL Product Based Export Controls are Found in the Commerce Control List The Commerce Control List contains much, though not all, of the information needed to determine if an item that is subject to the EAR is controlled (i.e., will require an export license). For some items subject to the EAR, the ECCN may also refer the user to another section of the EAR for further information as part of the determination whether a transaction party affects application of the control. For items not subject to the EAR (i.e., items whose export is subject to control by a different USG agency), the CCL will not provide conclusive information as to a requirement for an export license, though it may contain notes under the otherwise applicable ECCN to indicate control by the other agency. For example, the CCL contains ECCNs that describe defense articles which require a license application to the Department or State,DDTC The Commerce Control List (CCL) is published in the EAR as 15 CFR 774, Supplement1. (Links to an external site.) (Links to an external site.)Links to an external site. Although the CCL is included in the paper version of the EAR, because the CCL is subject to change on short notice in the Federal Register, we recommend always accessing it on-line to help assure the information is current. This also has the advantage of being able to use the browser search (find) feature to quickly locate information by key word (CTRL+f on a PC or ALT+f on a MAC), though care must be taken here to avoid misclassification. It is very important also to make sure your finds are in the correct category and product group. Finally, with Internet access, it costs nothing, whereas the paper publication is expensive. 15 CFR 738 (Links to an external site.) (Links to an external site.)Links to an external site. provides an explanation of the organization of the CCL, its relationship to the Commerce Country Chart (found in reading and resources) and provides step-by-step instructions on how to use the CCL to determine if an export license is required.   To more easily follow the CCL process, you should print out 15 CFR 738 and 15 CFR 774 Supplement 1 so you can refer to them as you read.  Locating the ECCN Determining the CCL Category There is no index of product names or descriptions for items within the CCL, so one has to understand and follow the organization of the CCL to determine if a particular product or material is addressed in the CCL. As you can see from 15 CFR 738.2 (Links to an external site.) (Links to an external site.)Links to an external site., the CCL is organized into ten (10) numbered categories which broadly describe the type of commodity or product. This number forms the first character in the ECCN, as follows: 0—Nuclear Materials, Facilities and Equipment and Miscellaneous 1—Materials, Chemicals, Microorganisms, and Toxin 2—Materials Processing 3—Electronics 4—Computers 5—Telecommunications and Information Security 6—Lasers and Sensors 7—Navigation and Avionics 8—Marine 9—Propulsion Systems, Space Vehicles and Related Equipment The first step in determining if a particular product or material is listed in the CCL is to identify this number from the product characteristics. Lets consider some examples of products, as might be described in a catalog or on a commercial invoice:   Personal computer – This is clearly Category 4, since it is a computer which is a specifically-named category. Bicycle helmet – By process of elimination, you can determine that this must be Category 1 since it clearly would not fall under any other description. Police helmet – By process of elimination, you can also determine that this must be Category 1 since it clearly would not fall under any other description. Weather radar – Since radar does not appear on the category list, it is necessary to read further into the listings of the possible categories radar might belong. Categories 3 and 6 would appear to be possible categories for weather radar, and perhaps even Category 7 if the radar were of the type installed in aircraft. How to proceed? Finding the correct CCL category for weather radar will require careful attention. Lets begin with a simple word search. Go to the on-line CCL (15 CFR 774 Supplement 1 (Links to an external site.) (Links to an external site.)Links to an external site.) and use your browser find feature (Ctrl+F) to search for weather radar. You will find weather radar appearing under one ECCN in Category 6, but only in a sentence that tells you that the particular ECCN does not apply. You then search for radar and find instances of this word under ECCNs in Categories 1, 3, 6 and 7. A word search of the CCL is an aid to finding a product listing, but is never conclusive. There will often be considerable attention to technical detail required. Remember, the CCL is mostly concerned with highly-technical items that the U.S. regulates the export of for national security or other specialized reasons. The vast majority of products exported from the U.S. are not specifically described anywhere in the CCL because their export is not controlled other than to countries against which the U.S. has trade sanctions, and so fall under the catch all ECCNs found at the end of each CCL chapter.   Determining the Group within the Category Each of these numbered CCL category sections is broken into the following five (5) groups further indicating the function of the product within the category: The second character in the ECCN indicates the group, as follows:   A—Equipment, Assemblies and ComponentsB—Test, Inspection and Production EquipmentC—MaterialsD—SoftwareE—Technology The second step in determining if a particular product or material is listed in the CCL is to identify this letter based on the product characteristics. Lets consider some examples of products, as might be described in a product catalog or commercial invoice:   Truck transmission – This is a component of a truck, so A would be the second letter of possible ECCN Computer operating system – This is software, so D would be the second letter of possible ECCN Engineering drawings – Since drawings comprise information about an item, rather than the actual item depicted in the drawing, this falls under technology, so E would be the second letter of the possible ECCN Chemical processing pump – This item would be used in Production Equipment, and so falls under B. Beryllium rods – This is a metal, in a basic shape that is non-functional except for further manufacturing, so C (materials) would be the second letter of possible ECCN Reasons for Control Reasons for Control The third character in the ECCN is a digit that indicates the primary reason for control of the particular commodity or product: 0—National Security reasons 1—Missile Technology reasons2—Nuclear Nonproliferation reasons3—Chemical & Biological Weapons reasons9—Anti-terrorism, Crime Control, Regional Stability, Short Supply, UN Sanctions, etc. reasons   From these high-level EAA export control objectives more specific reasons for control have been specified in the EAR for use in the Commerce Control List (CCL). Under the ECCN for an item, one or more reasons for control are listed using codes shown below. The current (as of September 08) reasons for control, by code, are:   AT – Anti-Terrorism CB– Chemical & Biological Weapons CC– Crime Control CW– Chemical Weapons Convention EI – Encryption Items FC– Firearms Convention MT– Missile Technology NP – Nuclear Nonproliferation NS– National Security RS– Regional Stability SI– Significant Items SS– Short Supply UN– United Nations Embargo SL– Surreptitious Listening Keeping these reasons for control in mind may help an exporter or freight forwarder recognize items (products, commodities) for which an export license will likely be required, and thereby help to avoid an accidental illegal export. For definitive determination, the ECCN for the item in question must be checked. Applying for Export License If an export license is deemed necessary, there are many steps that must be followed.   The application will require many support documents to verify the products export legality.   The purpose of a support document is to provide evidence that the prospective consignee and end user is legitimate and committed to compliance with U.S. export requirements. Under certain circumstances, an import certificate may also be required from the consignees government to verify the legitimacy of the consignee and confirm that the shipment will be allowed entry into the country. In a few circumstances for defense articles subject to the ITAR, a full import certificate/delivery verification procedure will be required.  This phrase, abbreviated as IC/DV procedure, describes a double procedure requirement used between certain cooperating governments to help assure that the export, subsequent import and use of sensitive controlled items is legitimate, and carried out in accord with an export license authorizing the export. The procedure begins with an import certificate issued by the destination government at the request of the importer through the export prior to shipment for used as a support document for his suppliers export license application. Once the export license is issued by the country from which the export is to be made, and actual shipment has been accomplished, in order to complete the process, a delivery verification certificate must be issued by the destination country customs authority to confirm that the subject shipment was, in fact, delivered to the particular consignee or end user authorized in the export license. When a support document will be needed for a U.S. export license application, the U.S. exporter should request the prospective foreign buyer/consignee to obtain it as soon as possible after the prospective export transaction has been agreed upon as it must be submitted together with the export application. Note: The requirement for a support document, when applicable, is in addition to a commercial document (for example, a sales contract, purchase order issued by the foreign buyer) documenting the real pending transaction. Commercial documents must always be submitted with an export license application along with product information (in the form of a sales brochure or written technical specifications), if such information is not already on file at the BIS from the particular applicant covering the particular product(s).   Types of support documents There are several types of support documents. The applicable ECCN listing may state the type of support document needed within the framework of the EAR, 15 CFR 748.9. Otherwise, refer directly to 15 CFR 748.9 to determine the requirement based on the destination country and reason for control. When required, a support documents will consist of one of the following:    Statement by ultimate consignee and purchaser —(See 15 CFR 748.9 (Links to an external site.)Links to an external site.; and, for a description of the form and exceptions, see 15 CFR 748.11 (Links to an external site.)Links to an external site..) This is the most commonly required supporting document, and is a U.S. form that requires completion by the foreign buyer and/or ultimate consignee (the destination government does not become involved). The PDF version of the blank form is available at BIS 711 Statement by Ultimate Consignee and Purchaser (Links to an external site.)Links to an external site. and a field-by-field description of the required information is available at 15 CFR 748, Supplement 3. (Links to an external site.)Links to an external site. Peoples Republic of China (PRC) End User statement (See 15 CFR 748.9; and, for a description of the form and exceptions, see 15 CFR 748.10. (Links to an external site.)Links to an external site.) When required, the end-user of the product or material to be exported in China must provide obtain this document from the Chinese government as specified in the EAR (above), and then provide this document to the prospective U.S Exporter in support of the prospective export license application. Import certificate —(See 15 CFR 748.9 and 15 CFR 748.10.) This is a form issued by certain countries listed under 15 CFR 748.9(b)(2). When required by BIS, this document is used in lieu of an end-user certificate. Import certificate/delivery verification procedure  For exports subject to the ITAR, the full IC/DV procedure may apply, with an import certificate (IC) required from the destination country as a condition of issuance of a DOS export license, as well as delivery verification (DV) following export. Refer to 22 CFR 123.14. This procedure is no longer used for DOC license applications. Firearms Convention Import Certification - This supporting document is required for exports consisting of firearms and related commodities, regardless of value, that are destined for member countries of the Organization of American States (OAS). Refer to 15 CFR 748.12. Refer also to Supplement 2 (Links to an external site.)Links to an external site.—Unique Application and Submission Requirements, and 15 CFR 748, Supplement 5 (Links to an external site.)Links to an external site. for a list of Validated End Users (VEUs). The answers can be found in the readings, and the links in the attached files. I want you to take your time and utilize the resources available to you for this these questions. Answer in complete sent Export License Coverage The goal is to provide you with a step-by-step approach to determining whether a particular contemplated export is subject to control(s) by the U.S. government (e.g., is not allowed for various reasons, requires an export license or other USG agency permit, is authorized under a license exception, and/or requires some form of reporting other than, or in addition to, a Shippers Export Declaration- SED (EEI)). This will serve as a primer on the subject for those initially learning about U.S. export controls and licensing. In this section we focus on how to determine what, if any, USG export controls or restrictions apply to a contemplated export. You will need to understand the previous modules on export policy objectives. This is oriented toward individuals who will be employed by exporters, freight forwarders and other who find themselves involved in facilitating U.S. exports which are subject to the U.S. Export Administration Regulations (EAR) and other USG export regulations. For this reason you will find a variety of operational recommendations and admonitions. Regardless of whether or not you are primarily responsible for determining export requirements or are actually initiating an export shipment, if you become involved in facilitating an export, you are responsible for compliance with the EAR and other USG regulations. If you are perceived by authorities to have acted with knowledge of a violation, you may become the target of civil or criminal enforcement action under the EAR or other USG laws or regulations. For a list or various things which violate the EAR, refer to 15 CFR 764.2 (which you can find using the links in the resource module.) This module is not an exhaustive treatment of all types of U.S. export controls, nor can it be used independent of the applicable USG regulations to determine specific export requirements and restrictions. I will not go over step-by-step instructions on how to apply for an export license—these are provided by the respective agencies as part of their application procedures. I will, however, provide links to this information plus sources of assistance from the respective agencies with license applications. In making actual determinations as to U.S. export requirements and restrictions, including whether an export license may be required, direct reference to and understanding of applicable USG regulations is required. Is License needed? Will a Particular Export Require an Export License or Other Pre-authorization? This information is intended to help exporters and their agents (typically freight forwarders) quickly recognize exports for which an export license is or may be required, or which may otherwise be restricted or illegal - it is important we notice red flags by having a basic understanding of why we restrict exports.   U.S. export controls are based on a combination of: Commodity (product) Destination,  Parties to the transaction Look over the following 2 flowcharts carefully: Decision Tree    Manufacturers, distributors and merchants who deal in a limited range of products have a relatively easy time understanding which prospective products, if any, may require a U.S. export license. A single phone call to the U.S. Department of Commerce (DOC), BIS Export Counseling Division may be conclusive for many exporters (see EAR, 15 CFR 730.8(c) for contact information). However, even with products that are not regulated, a prospective exporter or agent still has to be concerned with sanctioned destination countries and the parties they sell and/or shop to. Exporters of products containing certain advanced technologies, those having military uses, those that are used in enrichment of nuclear materials, those that are simply in short supply within the U.S., or are of interest to terrorists are likely to be subject to export restrictions. For these products, a prospective exporter may wish to seek a Classification Request from BIS to determine the applicable Export Control Classification Number (ECCN) which, in turn, will determine if such product is subject to product-based export restriction and licensing requirement. This list changes regularly, so it must be re-checked frequently. There is a convenient Internet web form for submitting classification requests or other inquiry to the BIS Export Counseling Division: the BIS Regulatory Inquiry Form (Links to an external site.)Links to an external site.. This is the informal way of seeking advisory assistance from BIS in anticipation of export opportunities. With respect to a particular contemplated export, for which the product, destination and parties are known, DOC (BIS) will also provide an advisory opinion as to whether or not a license is required. These procedures are explained in the EAR, 15 CFR 748.3 (Links to an external site.)Links to an external site.. Although infrequent, a particular contemplated shipment may also face non-product type restrictions which must be considered. These include a denial order or other sanction against one or more party(s) to the transaction. There are also reporting requirements and even bars to doing business with parties that request participation in restrictive trade practices. There is an excellent short overview of U.S. export controls on the BIS web site: See Export Control Basics. (Links to an external site.)Links to an external site. Exporters of sensitive commodities and technology may face complex determinations as to when or what type of export license may be required and/or the applicability of a license exception, or whether exports may be made at all to certain destinations. In such cases, advisory assistance from the DOC, legal advice and expert preparation of license applications may all be advisable. Acting on the behalf of others Freight forwarders and other agents that agree to act as exporter on behalf of a non-resident principal (FPPI) may face additional challenges and risks in determining the possible need for an export license and other export requirements. There are several reasons for this, including:   Limited product knowledge – An agent, particularly a forwarder, typically becomes involved with a more diverse range of products than would a typical exporter, but with much less understanding of the product specifications, what the products are used for, etc. Forwarders rarely have the technical knowledge needed to properly classify a product in the U.S. Munitions List (overrides the CCL)(USML) or Commerce Control List (CCL) (i.e., determine the ECCN). This is true even with the manufacturers specifications and data sheet. Dependence upon USPPI for information – An agent must depend on the accuracy and honesty of the manufacturer or supplier (USPPI (Links to an external site.)Links to an external site.) who is not its customer, for descriptions and specifications of the products they ship, and for full disclosure of the contents of packages. Consequently, as nominal shippers they face greater risk of making illegal exports while having full legal responsibility as exporter of record. When acting as applicant for an export license, an agents risk is further heightened since he becomes directly responsible for all the information supplied on the application, and for the assurance that what is subsequently exported does, in fact, exactly conform to the license. Time pressure – The first awareness an agent may have of a pending export is often very shortly before goods are ready for shipment. This is particularly true for freight forwarders. Yet it may take days to determine export requirements; and, if an export license is needed, additional time will be needed to assemble required export license application documents, apply for the license and receive one. The consignee (Links to an external site.)Links to an external site. may exert considerable pressure to ship during this time. Challenges for intermediaries Challenges for Intermediaries With respect to U.S. export controls, freight forwarders, 3PL professionals and other intermediaries, including all customer service and documentation staff, and especially managers and supervisors, should have sufficient understanding of export regulations to:   Provide sound advice. Answer basic questions which may be asked by clients; and then, if asked, redirect them to BIS or other expert help for direction on how such controls affect their particular products and transactions. Forwarders rarely have sufficient technical product, usage and market expertise to provide specific advice as to whether a prospective shipment requires an export license. Forwarders must know how and when to limit advise.   Identify shipments that require, or may require, an export license. This is essential before providing advice about export controls, and also necessary to recognize actual shipments that may require a license or are subject to other restrictions, but do not have a license. To make this determination, a forwarder must know how to classify items in the CCL from available information, and refer to other applicable regulations covered herein. Needed information to determine export requirements can typically be found in a shippers sales order, commercial invoice or quotation request document, and must include detailed product descriptions and destination party information. Just because a forwarder may be able to determine if an export likely requires an export license does not mean that a forwarder should be advising the shipper as to this. Understanding licensing requirements is needed primarily to avoid complicity in an illegal export.   Screen exports involving sanctioned parties. A forwarder must not handle an export involving a person or organization in the U.S. or elsewhere, including the shipper, consignee, ultimate consignee or a nominal consignee, that is subject to a denial order, other BIS sanction list, Office of Foreign Asset Control  (Links to an external site.) (Links to an external site.)Links to an external site.(OFAC) sanctions, or another sanctions list. There are now over a dozen separate government lists that must be checked with respect to sanctioned parties. Many forwarders now use automated services to routinely check against these lists as they enter transactions into their shipment processing systems. To ease the burden on those who do not, the U.S. Government has consolidated the various lists: Consolidated Screening List (Links to an external site.) (Links to an external site.)Links to an external site.. See heading Denied/Restricted Parties for much more on these lists and screening procedures.   Identify suspicious exports and avoid handling illegal exports based on an understanding of export regulations in general, and particularly from Know Your Customer Guidance and Red Flags in the EAR (ref. 15 CFR 732 Supplement 3). Step by Step Do I need a license For this part you will need to read through this information - it is 16 pages and technical, but it provides the necessary steps to determining license requirements.   You will be using this in both an assignment and a test so it should be read through carefully: https://www.bis.doc.gov/index.php/forms-documents/regulations-docs/142-eccn-pdf/file (Links to an external site.)Links to an external site. Also keep this FAQ for reference when completing assignments or tests.   https://www.bis.doc.gov/index.php/forms-documents/pdfs/286-licensing-faq/file (Links to an external site.)Links to an external site. General Prohibitions General Prohibitions Study this section: 15 CFR 736.2. (Links to an external site.)Links to an external site.   This section of the EAR sets forth, in a logical sequence, a step-by-step, hierarchical set of rules (prohibitions) that explain what a U.S. exporter or other U.S. person must NOT do—acts that will violate the EAA (Export Administration Act) and the EAR. When applied to a particular contemplated export transaction, these prohibitions will help determine whether the export is prohibited, will require an export license, may be made under a license exception, or may be freely exported as no license required (NLR). To apply this list of prohibitions, you must have the following information about a prospective export transaction: CCL classification of the item(s) – What are the ECCN(s)? Destination country(s) – What is the ultimate destination of the goods, and which intermediate country(s) will the goods pass through in-transit? Are any of these countries subject to U.S. trade embargoes, U.N. embargoes with respect to the item(s) being shipped, or unusual U.S. trade restrictions? Consignee and end-user – What is the nature and purpose of the end user, and is such party subject to denial orders, debarment (Links to an external site.)Links to an external site., OFAC sanctions or a party on the EAR Unverified Parties List (Links to an external site.)Links to an external site., a blocked entity or restricted entity? End-use and conduct – What are the circumstances of the transaction? How is the consignee expected to use or dispose of the item?  Other involved parties – None of the parties involved in an export, including exporter, forwarder, and intermediate consignees may be subject top denial orders, debarment, OFAC or other export sanctions. Much is summarized in the general prohibitions found here: http://www.ecfr.gov/cgi-bin/text-idx?mc=true&node=se15.2.736_12&rgn=div8 (Links to an external site.)Links to an external site.  (Links to an external site.)Links to an external site.  and will be summarized in the next section.  The answers can be found in the readings, and the links in the attached files. I want you to take your time and utilize the resources available to you for this these questions. Answer in complete sent Classification FAQ https://www.usitc.gov/faqs/tariff_affairs_faqs.htm Why do we classify products? Assigning classification numbers to products is important as the trade in goods increases on a global scale.   Numbers are not as easily misinterpreted or mistranslated as words.   This was the first reason behind product classification.    In order for it to work globally however, all countries need to use the same numbers for the same products.   This is what led to the Harmonized Tariff Schedule.    Harmonized meaning that all countries use it, at least the first 6 numbers.    The HTS (or HS) is used for imports and primarily to determine 1) what the product is and 2) determine what the import duty (tariff or tax) will be based on the country of export.   The US also had a classification for exports, the Schedule B.  This system was used to determine what was going OUT of the country and to compile the export statistics we use.   In order to make it work, we needed to make sure that our import and export classifications were aligned in some way.   What we see now is that the first 6 numbers of the HTS and the Schedule B are the same, with the final numbers being used for specific purposes that may differ between systems.  In a nutshell:  Why do you need to know your HS (Harmonized System)/Schedule B number? The HS number is needed to look up tariff rates the Schedule B number is needed to complete the Shippers Export Declaration the HS number may be needed on shipping documents, including certificates of origin the HS number is needed to determine whether a product qualifies for a preferential tariff under a Free Trade Agreement. HS numbers can also be used for market research purposes, such as identifying foreign markets where your product is currently being exported. Schedule B numbers are used by the Census Bureau to collect export data. The HS or HTS History: Back in the 1960s, major trading countries decided the world needed an internationally recognized system of tariff coding to facilitate global trade. Work on this classification system began in the early 1970s by the World Customs Organization (WCO Internationally the Harmonized System (HS) became effective on January 1, 1988. This system was designed as the core system allowing countries that adopted the coding to make subdivisions according to need and determine their own duty rates. The HS is now used by most countries throughout the world for both import and export purposes. This directly facilitates trade in a variety of ways, and also maks it possible for government, academic and private economists and policy makers to more precisely analyze and respond to world, national, industry and company trade data. Mastering tariff classification is a challenge, requiring not only systematic application of the General Rules of Interpretation (next section,) but also attention to the many notes found in the Harmonized System. The General Rule of Interpretation General Rules of Interpretation (GRI) These are part of the legal text of the Harmonized System consisting of six governing principles to be successively applied in the classification process. These rules are what make it possible to classify any commodity, product or article of commerce, including countless items which are not listed by their common or scientific name. Nations which have adopted the Harmonized System Convention are required to apply the GRIs without modification. The GRIs are part of the legal text of the HS tariff, are statutory provisions of law in most countries which have adopted the HS, and are intended to be consulted and applied each time merchandise is classified. See HTSUS General Rules of Interpretationfor listing of the rules. The function and effect of each rule can be summarized as follows: Rule 1 takes precedence over the remaining rules. It requires that classification be determined according to the terms of the HS headings and any relative section notes or chapter notes. If the texts of the headings and notes do not, by themselves, indicate the appropriate heading for the classification of merchandise, then it is to be determined by GRIs 2-6. This rule generally applies to articles that are specifically provided for or listed by name (sometimes referred to as eo nomine). Rule 2 contains two sections which deal with the classification of goods that, as imported, are incomplete or unfinished, unassembled or disassembled, or composed of mixtures or combinations of materials or substances. Rule 2 (a) has two parts. The first deals with incomplete or unfinished goods by extending the heading that refers to a particular article to include the article in an incomplete or unfinished condition, provided it has the essential character of the complete or finished good (e.g., an unpainted ceramic statuette). The second part deals with unassembled or disassembled goods by providing that complete or finished goods presented in an unassembled or disassembled condition are to be classified in the same heading as the finished article of which they have essential character. All unassembled or disassembled parts or components must be presented for entry at the same time (e.g., an unassembled bicycle containing all the parts and components necessary to build the bicycle). Rule 2 (b) governs the classification of mixtures and combinations of materials and substances by extending the heading that refers to a material or substance to include mixtures or combinations of that material or substance with other materials and substances; and governs the classification of goods consisting of two or more materials or substances by extending the heading to goods of a given material or substance to include goods consisting wholly or partly of that material or substance. This applies only if another heading does not refer to the goods in their mixed or composite state. If the addition of another material or substance deprives the imported good of the character of the kind mentioned in the heading being considered, one must resort to GRI 3. In other words, if mixtures and combinations of materials and substances, and goods consisting of more than one substance, are potentially classifiable under two or more headings upon initial consideration, they must be classified according to GRI 3. Rule 3 provides for classification of goods that are prima facie (or when initially considered) classifiable under two or more headings. In such cases, goods are classified according to this rule based on three criteria, taken in order: Rule 3 (a) provides that goods should be classified in the heading that provides the most specific description, name being more specific than class, and a description that more clearly identifies a product being more specific than one which is less complete. Furthermore, when two or more headings each refer to only one of the materials or substances in mixed or composite goods, or to only some of the articles included in a set offered for retail sale, those headings are regarded as equally specific, even if one gives a more complete description of the goods, one must resort to (b). Rule 3 (b) deals with mixed goods, composite goods, and sets offered for retail sale potentially classifiable in more than one heading (e.g., the good consists of two or more different ingredients, materials, components or articles and no heading provides for the good as a whole). Such goods are classified according to the ingredient, material, component or article that gives the good its essential character. If no one ingredient, material, component or article is found to impart essential character to the good, one must resort to (c). Rule 3 (c) provides that when goods cannot be classified by Rule 3 (a) or (b), the goods should be classified in the heading that occurs last in numerical order from among those equally considered. Rule 4 applies when goods cannot be classified according to Rules 1-3. This rule requires that the goods are to be classified under the heading appropriate to the goods to which they are most akin. In evaluating kinship, description, character, purpose or intended use, designation, production process and the nature of the goods should be considered. Since Rules 1-3 will cover the classification of most goods, this rule should be applied very infrequently. Rule 5 has two sections which deal with containers presented with the articles for which they are intended. Rule 5 (a) deals with long-term use cases, boxes and similar containers when presented with the articles for which they are intended. If they are the type of container normally sold with the article (e.g., a musical instrument case sold with the instrument), the container is classified with the article. This rule does not apply to containers that give the imported article its essential character (e.g., a silver dish containing sweets) which are classified under the heading for the container. Rule 5 (b) provides that containers not intended to be reused (e.g., containers holding food products) are classified with the articles they contain. This rule does not apply to packaging materials or containers suitable for repetitive use (e.g., metal drums) which are classified separately from their contents. Rule 6 prescribes that, for legal purposes, Rules 1-5 govern classification at the subheading level within the same heading. Once the appropriate heading has been identified, goods are classified in the subheading that most specifically describes them (in accordance with GRI 1-5). HTS Framework Most people refer to it as the Harmonized System (HS) or Harmonized Tariff System (HTS) The structure as a whole is also referred to as the nomenclature or the customs tariff. Any of these terms may be used. The chart below shows the framework or outline of the HS.   The HS is divided into sections. The sections are subdivided into chapters (the first two numbers) The chapters are subdivided into headings (the first 4 numbers) The headings are subdivided into subheadings (the first 6 numbers) Most sections and chapters have notes which provide mandatory instructions for classifying goods. There are also subheading notes regarding classification within subheadings. The General Interpretative Rules provide the overall context for classification. Navigation through the elements is governed by the General Rule of Interpretation. There are 21 sections, 97 chapters, about 1250 headings and 5000 subheadings within the core harmonized system HS Sections The Harmonized System is divided into 21 sections (numbered in roman numerals) each covering a group of commodities which would be the normal production of a given industrial sector. For example:   Sections I to IV cover the agricultural and food sectors. Section V is for basic mineral products. Section VI is for chemical products. Section XI covers textiles and apparel. Section XVI is for machinery and electrical equipment, including computers. Section XVII includes all vehicles, including spacecraft (!) (Have a look to grasp the scope but do not memorize!)   SECTIONNUMBER SECTION NAME CHAPTER Live animals; animal products 1 - 5 II Vegetable products 6 - 14 III Animal or vegetable fats and oils and their cleavage products; prepared edible fats; animal or vegetable waxes(Chapter 15) 15 IV Prepared foodstuffs; beverages, spirits and vinegar; tobacco and manufactured tobacco substitutes 16 - 24 Mineral products 25 - 27 VI Products of the chemical or allied industries 28 - 38 VII Plastics and articles thereof; rubber and articles thereof 39 - 40 VIII Raw hides and skins, leather, furskins and articles thereof; saddlery and harness; travel goods, handbags and similar containers; articles of animal gut (other than silk-worm gut) 41 - 43 IX Wood and articles of wood; wood charcoal; cork and articles of cork; manufactures of straw, of esparto or of other plaiting materials; basketware and wickerwork 44 - 46 Pulp of wood or of other fibrous cellulosic material; waste and scrap of paper or paperboard; paper and paperboard and articles thereof 47 - 49 XI Textiles and textile articles 50 - 63 XII Footwear, headgear, umbrellas, sun umbrellas, walking-sticks, seat-sticks, whips, riding-crops and parts thereof; prepared feathers and articles made therewith; artificial flowers; articles of human hair 64 - 67 XIII Articles of stone, plaster, cement, asbestos, mica or similar materials; ceramic products; glass and glassware 68 - 70 XIV Natural or cultured pearls, precious or semi-precious stones, precious metals, metals clad with precious metal, and articles thereof; imitation jewellery; coin 71 XV Base metals and articles of base metal 72 - 83 XVI Machinery and mechanical appliances; electrical equipment; parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles 84 - 85 XVII Vehicles, aircraft, vessels and associated transport equipment 86 - 89 XVIII Optical, photographic, cinematographic, measuring, checking, precision, medical or surgical instruments and apparatus; clocks and watches; musical instruments; parts and accessories thereof 90 - 92 XIX Arms and ammunition; parts and accessories thereof 93 XX Miscellaneous manufactured articles 94 - 96 XXI Works of art, collectors pieces and antiques 97 HS Chapters As much as it was possible, chapters were numbered in a sequence that tries to follow the degree of transformation of materials and goods. Raw materials are in lower chapter numbers; finished goods are in higher numbers. Looking at chapters on the Chapter and Heading List that you downloaded earlier, you will notice the upwards evolution:   Live chicken is in Chapter 1. A breast of chicken (raw) is in Chapter 2. Chicken cacciatore (cooked in tomato sauce) is in Chapter 16. Also   Iron ore is in Chapter 26. Steel plate is in Chapter 72. A cruise ship (made of steel plate) is in Chapter 89. One of the keys to becoming efficient at classification is a good knowledge of the structure of the chapters. This is what helps us make a first opinion of where to begin to classify a given merchandise. If you will be classifying on a regular basis, we recommend that you make a photocopy of the first two pages of the Chapter and Heading List and that, for a few weeks, you carry it with you and read it at least once a day to memorize the structure. e Divided into Headings A heading comprises 4 digits. The first two are the chapter number, the next two are the actual heading number within the chapter. The illustration for Chapter 79 shows only the headings and their respective descriptions. The picture on the right is a cropped page from the HTSUS (harmonized tariff system of the US)  showing the full 10 digit tariff item number including the heading, subheading and statistical suffix for shipments of these articles into the U.S., and their descriptions. In all national Harmonized Systems we will only be using the first six digits for this training, which are international.   Chapter 79 ZINC AND ARTICLES THEREOF Headings: 7901 Unwrought zinc 7902 Zinc waste and scrap 7903 Zinc dust, powders and flakes 7904 Zinc bars, rods, profiles and wire 7905 Zinc plates, sheets, strip and foil 7907 Other articles of zinc Whenever possible within a chapter the heading numbering reflects the degree of transformation of materials and goods. The example above reflects that numbering:  01 is rough, unwrought. 04 has been transformed into bars. 07 has been further transformed into an article of zinc. The text of the headings is one of the main elements of the HS, as we will soon demonstrate. HS Subheadings Headings are Divided into Subheadings   Subheadings are not born equal! Headings are divided into subheadings which form the final part of a full six-digit classification. In the excerpt below, a steel door lock for an automobile is classified in Heading 83.01 and in Subheading 8301.20.     8301   Padlocks and locks (key, combination or electrically operated), of base metal; clasps and frames with clasps, incorporating locks, of base metal; keys for any of the foregoing articles, of base metal   8301.10   - Padlocks   8301.20   - Locks of a kind used for motor vehicles   8301.30   - Locks of a kind used for furniture   8301.40   - Other locks   8301.50   - Clasps and frames with clasps, incorporating locks   8301.60   - Parts   8301.70   - Keys presented separately   There are one-dash subheadings and two-dash subheadings. We will refer to them in this course as dashes, even though they may only be represented by tabs in whatever HS book you are referencing. If you only have tabs, you may have a hard time determining where the tabs fall, it is easiest to use a ruler on the page or pages to see where the paragraphs line up. Two-dash subheadings are divisions of one-dash subheadings.   One-dash Subheading Example In the excerpt below, subheadings 41, 42 and 49 are two-dash subheadings subservient to the unnumbered subheading Other mountings, fittings and similar articles which would have been Heading 8302.40 if not further divided.      8302   Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat-racks, hat-pegs, brackets and similar fixtures; castors with mountings of base metal; automatic door closers of base metal   8302.10   - Hinges   8302.20   - Castors   8302.30   - Other mountings, fittings and similar articles for motor vehicles   - Other mountings, fittings and similar articles:   8302.41   - - Suitable for buildings   8302.42   - - Other, suitable for furniture   8302.49   - - Other   8302.50   - Hat-racks, hat-pegs, brackets and similar fixtures   8302.60   - Automatic door closers   A steel hinge for the door of a building is to be classified at 8302.10 (not 8302.41) because one must first find a suitable one-dash subheading before venturing to two-dash. The initial choices for the hinge are: - Hinges - Castors - Other mountings, fittings and similar articles for motor vehicles - Other mountings, fittings and similar articles - Hat-racks, hat-pegs, brackets and similar fixtures - Automatic door closer The fact that we are classifying a hinge puts it square into 8302.10, regardless of the tempting wording of 8302.41.   Two-dash Subheading Example In this table, find the subheading for a steel door stop for a building.     8302   Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat-racks, hat-pegs, brackets and similar fixtures; castors with mountings of base metal; automatic door closers of base metal   8302.10   - Hinges   8302.20   - Castors   8302.30   - Other mountings, fittings and similar articles for motor vehicles   - Other mountings, fittings and similar articles:   8302.41   - - Suitable for buildings   8302.42   - - Other, suitable for furniture   8302.49   - - Other   8302.50   - Hat-racks, hat-pegs, brackets and similar fixtures   8302.60   - Automatic door closers   The initial choices for the door stop are: - Hinges - Castors - Other mountings, fittings and similar articles for motor vehicles - Other mountings, fittings and similar articles - Hat-racks, hat-pegs, brackets and similar fixtures - Automatic door closer The door stop makes it to 8302.41. Here is how it looks in the HSTUS. I have used colored lines to show the tabs and how a straight edge can help show how the paragraphs line up. Familiarize yourself with this subheading hierarchy. Some headings are not subdivided. They have no subheadings. As an example, have a look at Headings 83.03 and 83.04 in your HS Book. In such instances the full six-digit classification of a good ends with two zeros. Based on this example, the six-digit classification of a fireproof steel safe would be 8303.00. Steps to Classifying Steps to Classifying Description of goods The first information about the goods that you have to classify will usually come from a suppliers invoice or customs form.  Unfortunately, often you need to know what the product is made from and what it will be used for. The description on such documents is very often insufficient to find the proper classification. For instance, a description reading: 12 chairs, model Sleekline #16A is certainly not sufficient to find a classification as you can see on the excerpt at right. You will have to know the constituent materials of the chairs, whether they are upholstered or not, etc. You would also need to know the use or purpose. Customs laws, customs regulations or customs directive demand that descriptions on invoices be detailed enough to fully classify goods. Compliance, however, is very poor. Traders claim that such descriptions would be hard to achieve with computer-generated invoices, would take too much space, etc. Seeing Goods as Presented Goods are to be classified as presented -- that is, in the state and condition that they are in, when presented for classification. Your first task is to look at what you are classifying globally. Is it a collection of unrelated goods or does it form a whole? Some goods will form a whole by virtue of a specific rule:  A guitar and its case, presented together: By virtue of Rule 5, the case will be classified with the guitar. A guitar case, presented alone: This will be classified as a case. Goods put up in sets or kits for retail sale, as presented, form a whole. You will have to use Rule 3 to find the one heading under which to classify an assortment of many things. Keep in mind, however, that they must be put together to meet a particular need or activity. You may have to classify everything separately. A shipment of spare parts, as presented, does not form a whole. Each item will have to be classified separately. Unless, of course, there are precisely the number of parts to assemble something that would then have the essential character of a machine (General Rule 2(a)).     Excess articles must be classified separately. If there were 8 pneumatic tires presented with this vehicle, 4 would be classified with the vehicle and 4 would be classified separately, as tires. Invoices with a long listing are a common pitfall for new classifiers. Make sure that you know what is presented for classification. Is it a list of parts or is it a whole? We once witnessed this poor lad who spent two and a half days finding classifications for each of the 2987 lines of a 60 page invoice. When he got to the last page of the invoice he noticed a line for Assembly and Labor with an amount equivalent to 35 percent of the whole invoice. Upon inquiring, he found out that the whole invoice was for one machine, all classified under one subheading. The manufacturer makes his invoices that way because each machine is made to the customers specification. The Schedule B The Schedule B represents the export classification codes for the US.   As with the HS numbers they come in the form of XXXX.XX.XXXX   with the first 6 numbers aligned with the HS numbers.   Here is an article that explains the difference between the two: Article Because the Schedule B has a search engine (link provide in the Useful Links section) it is often easier to try to find the heading and subheading using the schedule B and then switch over to the HTS site.  Instructions for using the search engine is next How to search for Schedule B number - https://www.census.gov/foreign-trade/data/video022.html