Comments on Informed Compliance Publication


Thank you for the opportunity to provide comments on the draft Informed Compliance Publication (ICP) on Bona Fide Sales and Sales for Exportation to the United States. We believe this is the first instance of U.S. Customs and Border Protection (CBP) providing an opportunity for the trade community to offer feedback on a draft ICP before it is published, and we welcome the transparency and prospect for constructive dialogue on this important issue. The First Sale Rule (FSR) is very important to RILA members, and many retailers utilize it to reduce their duty bills as envisioned by the statute. We also recognize CBP’s legitimate need to be able to verify FSR claims and believe that further clarification of the ICP would be helpful for both CBP and the trade community.


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