CBP Releases Guidance on Proving Admissibility Under Hoshine WRO
CBP posted an updated guidance document on proving admissibility for goods that are stopped due to the withhold release order aimed at silicon produced by Hoshine Silicon Industry, a company located in China's Xinjiang province, and its subsidiaries (see 2106240062). The guidance is "intended to provide information to the trade community including contact information on where to seek guidance on admissibility packages, tips for admissibility package submissions, processing expectations after initial supply chain verification, and advance rulings," CBP said in its description. The agency previewed much of the document during a recent webinar (see 2203070075).
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Demonstrating admissibility requires importers to "provide documentation produced in the ordinary course of business," CBP said. "Generally, documentation produced in the ordinary course of business includes full records of transactions and supply chain documentation to demonstrate all parties involved in the manufacture or export of a particular good, and the origin of the materials back to the suspected source of forced labor." The documents provided should be able to "give CBP a roadmap to easily navigate the documents and understand the production and importation story," it said.
CBP said its Electronics Center of Excellence and Expertise is handling the processing of most admissibility packages for the Hoshine WRO. "The Electronics Center and field audit teams are developing expertise in solar supply chains and are able to quickly understand supply chains that are substantially similar to those previously reviewed by the agency," it said. "As Centers gain expertise in particular supply chains, review times for related petitions improve." While a successful petition for admissibility is "likely to affect processing of future shipments," there isn't any guarantee for future shipments, the agency said.
Although processing of admissibility packages can depend on the specific case, "complete packages with all necessary documentation are currently being reviewed in as little as two to three weeks," CBP said. "Importers are highly encouraged to group shipments and containers with goods from the same supply chains, so that they can collectively submit them for review. The reduced complexity of shipments helps streamline petitions for admissibility and reduce petition review times."