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Monetary
Guidelines for Bond Amounts for
Special Category Merchandise
In the October 24, 2006 Federal Register, U.S. Customs and
Border Protection (CBP) published a notice on Monetary
Guidelines for Bond Amounts. The notice focuses on the
already in force bond guidelines for antidumping and
countervailing duties that were published July 9, 2004.
However, this notice seeks public comment on the procedures
for setting bond amounts on merchandise subject to increased
default risk and, therefore, designated as Special Category
merchandise that may be subject to enhanced bonding
requirements.
Special Categories will be designated when additional bond
requirements are determined, which could be in the form of a
larger continuous bond or other security. However, the
notice does not specifically state that only
antidumping/countervailing duties will be designated as
Special Category. CBP will provide notice of designation of
a Special Category on their website.
When a larger bond is required due to the Special Category
bond guidelines, CBP will allow the importer the opportunity
to submit the following as support for a lower bond limit
and proof that they are not/will not be a collection issue:
-
History of compliance with
customs laws and regulations
-
Past Payment history
-
Similarity to previous
circumstances giving rise to uncollected revenue
problems
-
Financial Stability
(independently audited financial statements, tax
returns, availability of assets, credit rating, length
in business, etc.)
Requests for
Reconsideration can be made only for Special Category
Merchandise six months after the demand for a new bond limit
has been made by CBP. This notice affects only continuous
bonds for imports of Special Category Merchandise. The full
version of the notice in the Federal Register can be viewed
here:
October 24, 2006 Federal Register.
Comments must
be received on or before December 26. Comments must be
submitted, identified by docket number USCBP-2006-0119 to
http://www.regulations.gov or mailed to Trade and
Commercial Regulations Branch, Office of Regulations and
Rulings in the Office of International Trade, U.S. Customs
and Border Protection, 1300 Pennsylvania Ave. NW (Mint
Annex), Washington, D.C. 20229. After consideration of any
comments received, the procedures will be incorporated into
the current Monetary Guidelines and published.
Avalon’s
Bond Merlin™ software will assist you in complying with CBP’s requirements. Avalon works closely with CBP to ensure
that the current version meets their criteria to file
continuous bonds with the NFC via e-mail. Avalon’s Bond
Merlin™ software is a network able, PC-based, product. Bonds
are reported on a 30 day schedule and all bond information
is stored locally on your computers. Our
Bond Merlin™ brochure provides more information about
this program.
For further information, please contact Christine Wade,
National Accounts Manager in our CBU Department or Gale
Lawton, Surety Manager at Avalon’s corporate headquarters.
Christine Wade can be reached at 847-700-8180 or via e-mail
at
cwade@avalonrisk.com. Gale Lawton can be reached at
847-700-8070 or via e-mail at
glawton@avalonrisk.com. Of course, please do not
hesitate to contact one of our nine regional offices
throughout the U.S. To view a directory of Avalon’s office
locations, please visit our Web site at
www.avalonrisk.com.
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