CBP HQ Considering Renewal of Pre-classification Program for Apparel Industries
CBP officials at agency headquarters are reviewing a proposal that would bring about a pre-classification program within the apparel Center for Excellence and Expertise, allowing importers that use the CEE to submit information to CBP and receive classification advice ahead of import, said CBP Director of Field Operations for San Francisco and Portland Brian Humphrey. Humphrey and others discussed the proposal March 7 during CBP’s Trade Symposium. The agency has previously mentioned the proposal (see 13102427), but has offered scant information in the past on how it might work. CBP has previously had such a program but has since stopped.
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The proposed program would make use of National Import Specialists (NISs) assigned to the CEE, said Humphrey, who noted he could not be too specific because the proposal is still being considered. The important thing for industry to know is that it would mean a single call into the CEE, after which CBP staff would take care of the rest, he said. Pre-classification is an issue that seems to go in and out of popularity, said Humphrey. “We put a proposal over to headquarters” to begin a pre-classification program at the apparel, footwear and textiles CEE, he said. “Pre-class is one of those things that, for all practical purposes, is very heavily concentrated in the apparel, footwear, textile arena, not so much others, so we believe it’s a natural fit,” he said.
While there’s no official pre-classification program at the moment, much of the same discussions occur as part of a company’s participation within the CEEs, said Matt Varner, director of Trade Operations of Nike. Though “not under the auspices of pre-class or line review,” the CEEs already work on such questions, he said. For instance, Nike raised an issue it noticed in the post-entry environment with the CEE, the question then went up to the NIS and after some dialogue, it was answered in “record time,” he said.
The idea also reinforces the benefit of the virtual nature of the CEEs, said Elena Ryan, director of the CEEs Transition Team at CBP. “While we are realigning our staff to better align by industry, and they are going to be able to do more and more virtually, not only as we evolve our thinking but also as we evolve our system,” there will still be CBP staffing sitting in the ports, she said. “We need our people where the cargo comes in. The cargo isn’t coming virtually, so we need our presence on the ground.” That applies to CEE employees involved in classification and valuation as well as the CBP officers, she said.
The pre-classification idea is one of the things the CEEs are considering to “move issues at the table” and get them resolved early, said Brenda Smith, CBP director-ACE business office, while talking to reporters after the conference. The CEEs are “looking at things either we have tried in the past or things we can think of now that can help with that predictability and help to get the issues off the table before the goods actually hit the border,” said Smith.