Thomas J Russo Metals Machinery Branch Chief National

Thomas J. Russo Metals & Machinery Branch Chief National Commodity Specialist Division (NCSD)- New York

NATIONAL COMMODITY SPECIALIST DIVISION (NCSD) § The NCSD is located at 1 Penn Plaza (previously 6 WTC) in New York and is composed of 48 National Import Specialists (NISs) and 45 National Import Specialist Assistants (NISAs) § The NISs are the recognized Commodity and Harmonized Tariff Classification experts in CBP § The NISs area of responsibility is defined and assigned by HTS number § The NCSD is a Division of the Regulations and Rulings (R&R) located in Washington D. C. § R&R is under the new Office of International Trade (OT)

National Commodity Specialist Division (NCSD) Division Director Branch 1 Metals & Machinery Electronics Heavy Machinery Steel Branch 2 Special Products Chemicals Food Wood Branch 3 Textiles & Apparel Wearing Apparel Fibers & Fabric Luggage

National Commodity Specialist Division (NCSD) Major Functions to Achieve National Uniformity and Informed Compliance § Technical advice to Headquarters and Other Government Offices/Agencies § Information/Advice to Field Offices § Risk Assessment/Database Maintenance § Advice to the Public

Technical advice to Headquarters and other government offices/agencies § CIT/Assistant Chief Counsel/Department of Justice case preparation, stipulations § International Agreements Staff – HQ – Review and comment on draft agenda matters before the HSC of the WCO § ITC – US Tariff language, new provisions, etc. § Commerce Department - AD/CVD scope determinations, new statistical breakouts

Information/Advice to Field Offices § Responding to internal electronic HTS classification questions from ports § Issuing internal electronic Alerts on HTS changes/issues § National Commodity Training Sessions (seminar program) § Mini-seminars/port visits – address issues specific to a port or group of ports § Email network messages or telephone contacts § Responses to Focused Assessment Team inquiries

Advice to the Public § Issue Binding Rulings – Classification, free trade agreements, country of origin, marking § Informed Compliance Publications § Informed Compliance Seminars, Commodity Specific Training Sessions § Presentations to trade associations – e. g. , LIIEA, AAEI, American Footwear Assoc. , etc. § Telephone advice – urgent or unusual issues, especially admissibility

Binding Rulings Authority 19 C. F. R. 177 Basic Requirements § Name, address, email address, of requesting party § Description of transaction - Prospective v. Current § Statements – No issues pending § Complete description of goods in imported condition § Type of Ruling Request (e. g. Classification etc. )

Types of Rulings § Classification § Marking § Country of Origin § Free Trade agreements

e. Rulings program § Via email since 2003 § e. Rulings Template created in December 2005 § Found on CBP. gov § Fill in the blanks § Attach Pictures, Illustrations, Manuals § Electronic signature § Electronic Ruling Program eliminates mailing on both ends to reduce overall processing time and expedite receipt of decisions. § EXCEPTION - No samples permitted

BY THE NUMBERS § A total of over 9000 binding ruling requests were filed in FY 2007. § Over 25% or approximately 2, 400 requests were e. Rulings. § Over 2000 ( 225 per month) since the start of the new web template in December of 2005. § Average response time is approximately 20 days.

KEY BINDING RULING CBP WEBSITES § CBP Main Site - http: //www. cbp. gov/ § What are Rulings § http: //www. cbp. gov/xp/cgov/toolbox/legal/Rulings/ruling_letters. x ml § e. Rulings Requirements http: //www. cbp. gov/xp/cgov/toolbox/legal/Rulings/e. Ruling. Require ments. xml § e. Rulings Template § https: //apps. cbp. gov/erulings/index. asp § Customs Rulings Online Search Systems - CROSS http: //rulings. cbp. dhs. gov/