Introduction: Paying Duty on the Right Price When goods pass through multiple intermediaries before reaching the U.S. importer, each transaction adds a markup. Under the default customs valuation rules, duties are assessed on the final transaction value: the price the U.S. importer pays to the foreign seller. But if there is an earlier sale in…
Valuation Is the Foundation of Your Duty Calculation If classification determines the percentage rate, valuation determines the dollar amount to which that percentage is applied. Valuation errors affect every product at every duty rate and can be equally or more significant than classification errors. Understanding the Transaction Value Method The transaction value is the price…
The Case for Auditing Your Own Import Program A voluntary compliance audit identifies errors before the government does, giving you the opportunity to correct them through voluntary disclosure, which dramatically reduces penalty exposure. It also identifies overpayments that can be recovered through refund claims. What a Compliance Audit Covers Classification accuracy, valuation practices, country of…
Answer Capsule Customs valuation determines the taxable base for import duties and is a critical cost driver for all EU importers. The EU applies six WTO-derived valuation methods in strict hierarchical order, with transaction value (the actual price paid) as the primary method in most cases. Importers must understand additions to transaction value (freight, insurance,…

The First Sale Doctrine Under Legislative Siege Senators Cassidy and Whitehouse have introduced the Last Sale Valuation Act, legislation that would fundamentally restructure how U.S. Customs calculates duties on imported goods. The act would eliminate the First Sale Doctrine, which allows companies to calculate duties based on the price at which a foreign manufacturer sells…

CBP’s Renewed Focus on First Sale Valuation Methodology U.S. Customs and Border Protection has intensified scrutiny of First Sale valuation methodology through targeted questionnaires and outreach to importers. Recent CBP communications request that companies document whether they have used First Sale valuation between 2023 and 2025, and if so, whether supporting records exist. On the…

Introduction: A Fundamental Shift in Customs Valuation Recent guidance from Her Majesty’s Revenue and Customs (HMRC) has established a pivotal precedent in how customs authorities assess the value of imported goods within multi-entity business models. The latest B2B2C (Business-to-Business-to-Consumer) valuation ruling represents far more than a technical interpretation of trade regulations. It signals a definitive…