How We Successfully Addressed an ADD/CVD Inquiry on Engines for Customs

At Just Your Broker Inc., we take pride in staying up to date on best practices in import compliance by actively participating in Customs webinars. Recently, one of those best practices proved invaluable.

Our client imported an engine for a horticultural machine. After transmitting the entry, an ADD/CVD alert appeared. To address this, we reviewed the applicable scope ruling and confirmed that the engine did not fall within its scope. About a week later, Customs requested an entry summary packet, which we promptly uploaded. A few days later, we received a follow-up message stating that we had 10 days to provide evidence that the engine was outside the scope.

Understanding the urgency of responding to Customs, we immediately contacted the importer to inform them of the request. Together, we reviewed the scope ruling again and asked the importer to provide the engine’s manual and pictures.

Upon thoroughly reviewing the scope ruling, we confirmed that it applied only to engines with vertical shafts, whereas our client’s engine had a horizontal shaft. Our goal was to find documentation explicitly identifying it as a horizontal engine rather than a vertical one, as this distinction was crucial in determining whether it fell outside the scope. To support our case, we drafted a detailed letter explaining why the engine did not meet the scope requirements. We included pictures of the engine and its emissions control information label. Additionally, we cross-referenced the EPA’s database for small non-road spark-ignition (NRSI) engines, which allowed us to verify the engine’s specifications. Our findings confirmed that the engine was listed with a horizontal crankshaft orientation.

Within three hours of submitting our response, we received confirmation from Customs that the entry would be accepted as originally filed.

When you're ready to experience The Power of Good Advice, reach out to us. We’d be happy to assist you. Let Just Your Broker Inc. be your trusted Customs broker.