CBLE Import Compliance and Risk Management 3 — Questions and Answers
Question 1: Reasonable care under 19 U.S.C. § 1484 requires the importer of record to do which of the following?
- Hire a licensed customs broker for every shipment
- Make entry using information that is accurate and complete to the best of their knowledge (Correct answer)
- Obtain a binding ruling before each importation
- Submit all invoices in English before filing entry
Correct answer: Make entry using information that is accurate and complete to the best of their knowledge
Section 1484 places a legal duty of reasonable care on importers to provide accurate, complete information when making entry, regardless of whether a broker is used.
Question 2: An antidumping duty (ADD) cash deposit rate is assessed at the time of entry. When is the final ADD rate determined?
- At time of importation based on current rates
- During an administrative review after the entry period (Correct answer)
- By the International Trade Commission at liquidation
- By the WTO Dispute Settlement Body within 60 days
Correct answer: During an administrative review after the entry period
ADD cash deposit rates are preliminary; the final rate is set during an annual administrative review conducted by the Department of Commerce, which can retroactively change the duty owed.
Question 3: Which CBP form is used to formally protest a CBP decision on a liquidated entry?
- CBP Form 19 (Correct answer)
- CBP Form 28
- CBP Form 29
- CBP Form 4647
Correct answer: CBP Form 19
CBP Form 19 is the Application for Further Review of Protest used to contest CBP's decisions on rate or classification after liquidation.
Question 4: A shipment of goods arrives and CBP suspects they may be subject to a detention order from another agency. Under what authority can CBP detain the goods?
- 19 U.S.C. § 1499 — Examination of merchandise (Correct answer)
- 19 U.S.C. § 1526 — Recordation of trademarks
- 19 CFR Part 12 — Special classes of merchandise
- 19 U.S.C. § 1641 — Customs broker licensing
Correct answer: 19 U.S.C. § 1499 — Examination of merchandise
CBP uses its authority under 19 U.S.C. § 1499 to examine and detain merchandise while it coordinates with partner government agencies that have enforcement jurisdiction.
Question 5: An importer voluntarily discloses a pattern of undervaluation errors before CBP detection. Under the penalty mitigation guidelines, this disclosure typically results in what outcome?
- Automatic criminal referral to DOJ
- Significant reduction or elimination of penalties (Correct answer)
- Mandatory debarment from importing for one year
- Automatic seizure of all affected merchandise
Correct answer: Significant reduction or elimination of penalties
CBP's penalty mitigation guidelines provide substantial relief — often reducing penalties to zero or a nominal amount — when importers voluntarily disclose violations prior to CBP inquiry.
Question 6: The ISF (Importer Security Filing) '10+2' rule requires the importer to submit which of the following data elements?
- Seller, buyer, HTSUS number, and country of origin
- Manufacturer, ship-to party, HTSUS number, and container stuffing location (Correct answer)
- Carrier, vessel name, port of unlading, and estimated arrival date
- Importer of record, consignee, and bonded warehouse address
Correct answer: Manufacturer, ship-to party, HTSUS number, and container stuffing location
The 10 importer-provided elements include manufacturer, seller, buyer, ship-to party, container stuffing location, consolidator, importer of record number, consignee number, country of origin, and HTSUS number.
Question 7: Under the Foreign Trade Zones (FTZ) program, merchandise admitted into an FTZ in 'privileged foreign' status has its duty rate determined at what point?
- At the time of admission to the zone (Correct answer)
- At the time of entry into U.S. commerce
- At the time of manufacture within the zone
- At the time the weekly entry is filed with CBP
Correct answer: At the time of admission to the zone
Privileged foreign status locks in the tariff classification and duty rate as of the time the merchandise is admitted to the FTZ, protecting the importer from future rate increases.
CBLE Import Compliance and Risk Management 3
Reasonable care under 19 U.S.C. § 1484 requires the importer of record to do which of the following?