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November 2001
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Import Specialists: The puzzle solvers

By Elysa Cross, Writer/Editor, Office of Public Affairs

If I ever wanted a new career in Customs, I would like to be an import specialist. I've always enjoyed puzzles and the work that import specialists do seems like just that - a puzzle - making sure that imported merchandise is classified properly, that its value and country of origin are correct, and the right amount of duty is being charged. When I was offered an On Location piece for U.S. Customs Today, I thought, this is my chance to see what an import specialist really does. What I found out made me realize that an import specialist's work is a lot more complicated and more important than I ever imagined.

Blaine, Washington, is located at the north end of Puget Sound where Interstate Five meets the Canadian border. It's about a two-hour drive north on I-5 from Seattle, and 30 minutes south of Vancouver, British Columbia. Blaine's 3500 residents believe its close proximity to Puget Sound waterways, the Alaska ferry, Mt. Baker, the Gulf Islands, and ski and recreation areas make it a wonderful place to live and work. The combination of I-5 and two of the busiest U.S. Customs ports of entry on the Canadian border, a passenger and a cargo crossing, brings an average 75,000 visitors each day through the community for sightseeing, shopping, eating, and traveling on to points beyond Blaine.

So what exactly does an import specialist do?
Import specialists classify commercially imported merchandise to assess Customs duty and any other applicable government agency fees. This is done by examining the merchandise, reviewing the results of laboratory analyses, interviewing importers, or by examining their business records. They also verify the admissibility of merchandise and applicability of quotas and other import restrictions; verify the classification, the value, and compliance with a wide variety of government regulations; and they enforce provisions of the Tariff Act and other agency's laws and regulations regarding value, quota limitations, endangered species, trademark and copyright protection.

I was greeted by Jill Peck and Marcia Dewyea, two of the import specialists on team 796. This team is responsible for classifying live animals, animal products, food products, beverages, alcohol, tobacco, textiles, arts and antiques, footwear, headwear, wood and wood products, paper products, pillows, mattresses, prefabricated buildings, pens and pencils, brooms, brushes, buttons, zippers, typewriter ribbons, lighters, combs, vacuum flasks, and many other commodities.

There are two other teams of import specialists at Blaine, team 795 and team 797, responsible for classifying all the other commodities. I was amazed at the amount and types of things that are imported, and that at Blaine, it's all handled by 10 associates (team members), five team leaders, one technician, and one supervisory import specialist. According to Lorisa Hubsch, team leader for Team 797, "There is never a dull moment, I'm always learning something new, and everyday it's something different."

Jay Brandt, the Assistant Port Director for Trade, explained to me that Blaine is an Area Service Port for the ports of Lynden, Sumas, Friday Harbor, Pt. Roberts, Oroville, and other ports in Washington State. When he started at Blaine in 1971, a busy day was processing 150 trucks. Today, 1700 to 2000 trucks are processed each day.

Since the advent of the North American Free Trade Agreement (NAFTA) there has been a decrease in the amount of duty collected, but there are more trade program issues to deal with such as the softwood lumber issue, quota evasion schemes, NAFTA verifications, and port account management.

Fish fillets or fish steaks?
Import specialists often use the Internet to access a manufacturer's Web site to get information on their products. They also look in the Treasury Enforcement Communication System (TECS) to determine if a particular company has any prior infractions. They send requests for samples and for verification that the product is actually made where and how the exporter claims. For example, a Canadian company that produced a meat substitute claimed NAFTA qualification under a tariff shift. (They used a type of yeast that, classified by itself, did not qualify for NAFTA, but the company claimed that because it was incorporated into their meat substitute it now qualified.) After careful investigation through the Harmonized Tariff Schedule it was determined that the product did not qualify for NAFTA. The company has since changed the type of yeast used and now they do qualify for NAFTA, however, they protested the reclassification of the non-qualifying goods, and the issue is now being decided at headquarters. In cases like this, NAFTA verifications can take anywhere from one month up to several years to complete.

Import Specialists Marcia Dewyea and Jill Peck, along with Senior Inspector Bill Wyder, inspect lumber arriving from Canada.
Photo Credit: Photo by Gerald L. Nino
Import Specialists Marcia Dewyea and Jill Peck, along with Senior Inspector Bill Wyder, inspect lumber arriving from Canada.

A random 5 percent of NAFTA verifications have to be completed by an actual visit to the manufacturer. (Another of my passions - factory tours.) The Blaine import specialists have visited garden umbrella factories, flower auctions, fisheries, paper factories, apparel factories, chocolate candy factories, and other Canadian manufacturers.

Import specialists are also responsible for doing Census compliance exams. The Department of Commerce compiles statistics on the value and quantity of imported items. These statistics are put into a computer, which produces a Census error message for items that are outside of the parameters. For example, Commerce finds that a particular classification of fish from a certain country of origin should cost between $.30 and $.50 per kilogram (kg.). If fish in that classification is entered at $.80 per kg., the computer will flag the entry and the import specialist will contact the shipper to confirm the type and price of the fish. The shipper may have misclassified fish fillets as fish steaks.

The truck inspection building at the port of Blaine, which also houses the administrative offices; Entry Division; Fines, Penalties and Forfeitures; and the Import Specialist Division, is new, only about 2 years old. This makes the Port of Blaine unique in that the entry specialists and import specialists are located in the same building with the inspectors and the cargo. "I like working here because we are so close to the cargo," says Dewyea. "If something comes in we can go down to look at it now and not next Thursday."

Putting together the puzzle
Knowing that I was on location for U.S. Customs Today, an inspector called to say that a shipment of jewelry marked as U.S. goods returned for repair had been detained because there was a question of the value of the goods and of the country of origin. When the importer was questioned he said that the jewelry was really scrap. Kay Hickman, one of the team leaders for team 795, Shelley Crawford, an entry specialist, and I went to look at the jewelry. We unpacked a number of the pieces - the jewelry looked undamaged and had price tags attached - it certainly didn't appear to be scrap. The next step was to check to see if the importer is indeed the manufacturer and why the entry was changed from "U.S. goods returned" to "scrap." After the importer/manufacturer was contacted, he did recant his claim that the goods were damaged. The importer was instructed to use the correct value, which would be the wholesale cost to dealers. The shipment was entered under the provision for U.S. goods returned and released.

A shipment of Baltic birch came through from Russia and, because the import specialists also do compliance assessment exams, Jill Peck and I went down to look at it. The plywood had been clearly marked as a product of Russia, and the molding had been worked on both sides making the classification correct, so the shipment was released.

Working in cooperation with the NIS
National import specialists (NIS) located in New York input criteria into the Automated Commercial System (ACS) for possible false country of origin or other discrepancies. That, in turn, alerts the local import specialists that they need to take a closer look at all cargo entries with those particular criteria. The local import specialists can also request that the national import specialists enter criteria if they are noticing a trend in certain types of discrepancies. The criteria can even be narrowed down to a particular shipper if he only has one type of commodity. The relationship between the NIS and local import specialist is a critical factor in the success they have achieved together.

The import specialists need to know a lot about the commodities their teams are responsible for and rotate periodically to other teams. They are free, however, to choose commodities within their team in which to specialize. Says Jill Peck, "I have the opportunity to pick something that interests me, like carpets, and learn all about it."

In the two days that I spent with the import specialists at the Port of Blaine, I learned that the job was just as interesting as I thought it would be, and a lot more involved and complicated. I left with an increased respect for the people that perform this very important work and I still think that it would be a job that I would like to do - if I were going to change careers.

Verify and validate
All of the import specialists on team 796 are members of the Textile Production Verification Team (TPVT) located at Headquarters. The TPVT forms smaller teams to conduct onsite reviews at foreign factory locations. The teams are made up of import specialists, agents, and international trade specialists. These teams travel around the world visiting manufacturers that may pose the highest risk for engaging in illegal transshipment to determine if the manufacturer is capable of actually producing the types and amounts of textiles that they export. The TPVTs also verify that the employees have the necessary skills to perform the job.

The risk for illegal textile transshipment increases when duty-free and quota-free treatment is extended to any of our trading partners. One critical approach to addressing this threat is the ability to verify and validate production through access to information and to the foreign factory.

Currently 32 import specialists and a like number of investigators are trained to do this work. Each year the team travels to 7-10 countries and visits approximately 400 factories. Each visit takes anywhere from 15-30 days depending on the level of verification and number of factories involved.


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