The SnowSports Industries Association is asking its members to submit comments to it by close of the day Friday on a proposed change to federal regulations that the trade group says could double duties on many goods imported by its members.
Customs now proposes to change the price on which it bases its ad valorem duty calculation to the price paid by the last buyer before the goods are physically introduced into the United States. This new rule would be a “last sale” rule. As such, duties would be based on the higher price of goods at the end of the wholesale supply chain.
How duties might double
More details on the proposed change are available in Volume 73 of the Federal Register, pages 4254 through 4264 (Customs and Border Protection Notice of Proposed Interpretation and Solicitation of Comments, issued January 24, 2008). SIA will send a copy of this Federal Register notice upon request.
Industries uniting to submit comments
If you believe that your company will be adversely affected by a change to a “last sale” rule, SIA wants to hear from you. In particular, please consider the following questions:
- Are you currently claiming the price of the “first sale” from the manufacturer for valuation purposes when you import goods? If not, what price are you using?
- How many times do your goods change hands along the wholesale supply chain?
- How would an increase in duties affect your competitiveness?
- Do you feel you could pass on price increases to consumers?
- Is there any chance that this increase in duties charged could force you out of business?
- What is the percentage increase in price between (a) the price of the first sale from the manufacturer of the goods and (b) the sales price to you upon the arrival of the goods in the United States?
SIA asks members to e-mail responses to this request for information to Shaun Corette at email@example.com no later than Friday, March 7, 2008. We welcome any additional comments you may have in response to Customs' proposed change to a “last sale” rule, and, as always, we are available to respond to any questions you may have. If you have additional comments or questions please contact either Shaun Corette at 202-799-4201 or firstname.lastname@example.org;or Kate Mueller at 202-799-4112 or email@example.com.