The U.S. Customs and Border Protection binding ruling program enables importers and other interested parties to get binding pre-entry classification decisions prior to importing a custom product, and filing entries with Customs and Border Protection (CBP). It is also used to get binding guidance about other CBP regulations pertaining to marking of country of origin requirements. The E-rulings (Electronics Ruling) program allows for faster and easier method for U.S. companies using China manufacturing services to generate custom products.
The electronic request for binding rulings can be sent to the National Commodity Specialist Division via an easy-to-use template. The e-rulings template is for use only for the submission of initial ruling requests and any follow-up questions must be made by phone to the Office of Customs and Border Protection. Below are some details as to has the new e-rulings will affect the protection of intellectual property and the use of offshore manufacturing.
Information Needed in a Ruling Request
E-ruling requests must contain a comprehensive statement of all facts relevant to the transaction:
- The name and contact information of the requestor
- The names and contact information of all other interested parties as well as the manufacturer’s ID code
- The name of the port where merchandise is to be entered
- A brief description of the related transaction. For instance, a potential import of merchandise from China
- A statement that there are no issues pending before the CBP or another court
- A statement on whether the requestor has sought advice from a CBP office
Classification of Imported Custom Products
Classification rulings help to determine which HTS provisions apply to imported custom products. A product’s classification depends on a variety of factors.
- A complete description of the goods in the same condition in which they are imported
- A listing of component materials
- Plans for the goods’ usage in the U.S.
- The technical, common and commercial designation
- Chemical analyses and CAS numbers
Origin Country Designation
Marking and country of origin rulings help clients determine whether goods are properly labeled as to their origin country. In making this determination, certain information is used:
- A detailed description of the article and container’s markings
- Illustrations showing how goods are packaged and labeled
- A description of how goods will be sold or used on importation to the U.S.
More information on the E-Ruling system can be found on the U.S. Customs and Border Protection website. Go to https://www.cbp.gov/trade/rulings/eruling-requirements
If you have questions on China manufacturing and how to best take advantage without being taken advantage of call ITI Manufacturing. We’ve been helping US-based companies manufacture more economically and successfully in China for over 40 years.
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