How to Prepare a Customs Compliance Manual

Jo-Anne Daniels

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Description of the topic:

 One of the most significant effects of the Mod Act is the establishment of the clear requirement that parties exercise reasonable care in importing into the United States. Section 484 of the Tariff Act, as amended, requires an importer of record to use reasonable care to make entry by filing such information as is necessary to enable CBP to determine whether the merchandise may be released from CBP custody, and using reasonable care, complete the entry by submitting with CBP the declared value, classification and rate of duty and such other documentation or information as is necessary to enable CBP to properly assess duties, collect accurate statistics, and determine whether any other applicable requirement of law is met.  Importers must implement processes and procedures and then document these in a Customs Compliance Manual. U.S. Customs and Border Protection provides a list of questions that help importers develop a framework for a compliance manual and program and meet reasonable care standards.  The webinar will discuss the basic elements that should be included in the compliance manual.


On December 8, 1993, Title VI of the North American Free Trade Agreement Implementation Act (Pub. L. 103-182, 107 Stat. 2057), also known as the Customs Modernization or “Mod” Act, became effective. These provisions amended many sections of the Tariff Act of 1930 and related laws.

Two new concepts  emerged from the Mod Act which  are “informed compliance” and “shared responsibility,” which are premised on the idea that in order to maximize voluntary compliance with laws and regulations of CBP, the trade community needs to be informed of its legal obligations and  must use reasonable care  under Section 484 of the Tariff Act, as amended (19 U.S.C. § 1484.


Why should you attend?

Customs expects all importers to have a written customs compliance program and procedures in place to ensure that import entries are submitted correctly.  The customs compliance manual must be accessible to all employees who are involved in the importation process.  This webinar is targeted to those individuals managing the corporate import program, such as, Legal, Finance, Import/Export Compliance, Logistics and Supply Chain.

Areas Covered in the Session:

  • Identity and document the responsible and knowledgeable individuals within your organization responsible for the Customs Compliance program who has oversight of customs documentation and manages the customs broker.
  • Describe your Customs Compliance structure and explain how your company can ensure that import group is supported by senior management.
  • Document who is outside expert to assist your complying with customs requirements.
  • Describe how your company has established reliable procedures to ensure you provide a correct tariff classification of your merchandise to CBP in accordance with 19 U.S.C. § 1484?
  • Document how your company has established reliable procedures to know the price actually paid or payable for your merchandise.
  • Describe the tools your company uses to ensure compliance: CBP valuation laws and regulations, Customs Valuation Encyclopedia, CBP's informed compliance publications, court cases and CBP’s rulings on CROSS.
  • Document how your company has used reliable measures to ascertain the correct country of origin for the imported merchandise.
  • Explain Foreign Trade Agreements and how your company complies.
  • Describe what measures  have been developed  to determine if your goods are subject to a Commerce Department antidumping or countervailing duty investigation or determination, and if so, have you complied or developed reliable procedures to ensure compliance with customs reporting requirements upon entry (e.g., 19 C.F.R. § 141.61)?
  • Document how your company complies with the Section 301 Duties.
  • Include how your company has adopted a Social Compliance Initiative to fight Forced Labor
  • Explain the broker management process and import documentation flow.
  • Document your internal and external audit procedure? Include ISA program if it exists at your company.
  • Describe what actions will be taken to correct entries if an error is found and file Post Summary Corrections.
  • Document the internal escalation process if a violation of 1592 is found.

Who will benefit: 

Every person involved in the import process will benefit from this webinar.

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Speaker: Jo-Anne Daniels, President, Trade Resources & Associates

Jo-Anne Daniels, is a Licensed Customs Broker for 25 years. Ms Daniels is the President of Trade Resources & Associates, a consulting firm providing international trade services to corporations and has been responsible for global trade compliance for multinational corporations, such as, Aviza Technology, Inc., Solectron Corporation, Applied Materials, and Siemens. She specializes in Customs, Commerce, and ITAR compliance assessments, executive awareness training, export and import classification guidance, supply chain security reviews and C-TPAT certification. She has been a featured guest speaker for trade associations, logistic organizations, a guest lecturer at Golden Gate College. Ms.Daniels is a published writer, trainer, and President of the Professional Association of Exporters & Importers.

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