CBP Should Clarify Ability to File Protests Covering Multiple Ports With CEEs, USFIA Says
CBP should make clear if it intends to allow for protest filings at the Centers of Excellence and Expertise to cover multiple ports of entry, the United States Fashion Industry Association said in comments to the agency (here). The USFIA comments were part of CBP's docket on interim regulatory changes for the CEEs (see 1612190014). "Since this is a major change in protest procedures, USFIA suggests that Section 174.12(d) be further amended by adding: 'A protest filed with the Center director may include entries filed at multiple ports of entry,’” the USFIA said. CBP extended a comment period on the interim rules, which went into effect on Jan. 19, to allow for more participation (see 1701260010), though other comments were filed previously (see 1701250019).
Sign up for a free preview to unlock the rest of this article
Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.
Also unclear is whether all protests and other communications with the CEEs are required to be submitted electronically, the USFIA said. While Section 174.12(d) indicates that protests at the CEEs be electronic, that seems to contradict the regulations elsewhere, it said. "If that is the requirement, it should be explicit. USFIA would oppose any such requirement unless there is an equally explicit statement that the requirement shall be waived in appropriate circumstances," the group said. "One such circumstance comes immediately to mind -- production records necessary to establish origin or preference eligibility, which can be voluminous.”
Comments from lawyers at Adduci Mastriani also were recently posted (here). The lawyers, Munford Page Hall and William Sjoberg, were complimentary in their comments. The lawyers said they have had very good interactions with multiple CEEs and singled out several individuals that were helpful. "Our experiences with the Centers to date are mostly very positive," they said. "We believe that the Centers have generally proved to be a vast improvement over the often disjointed and inconsistent treatment that resulted from having to deal with individual Ports of Entry directly.”