April 4, 2008
American Sportfishing Association Policy Alert – Import Duty First Sale Rule
ASA Opposes U.S. Bureau of Customs and Border Protection’s Proposed Import Duty Rule Regarding “First Sale”
For more information, contact Gordon Robertson, vice president and Government Affairs lead, 703.519.9691, x237, or Patty Doerr, Ocean Resource Policy director, x244.
How You Can Help
The U.S. Bureau of Customs and Border Protection (CBP) has proposed an import duty rule regarding “first sale” that will reverse a well-settled practice of customs valuation. This rule could have significant negative impacts on sportfishing businesses if it is approved. Please submit comments urging the CPB to withdraw the new import duty “first sale” proposal from consideration. The deadline for comments has been extended to April 23, 2008. To submit comments, go to Regulations.gov, the federal government Web site which facilitates public comment on federal regulatory actions. Use the “Add Comments” function to add your own comments or copy and paste the following comments into the General Comments section.
I oppose the U.S. Bureau of Customs and Border Protection (CBP) proposed import duty rule regarding “first sale.” This unilateral and arbitrary proposal to reverse a well-settled practice of customs valuation based on the “first sale rule” will undermine nearly 20 years of U.S. Federal Court jurisprudence. I believe it will raise U.S. consumer prices. It will also have a significant negative impact on U.S. companies who have relied on this practice which now may be forced to restructure and revise business practices that have been built around this practice of valuation.
This import duty rule was proposed with no advance notice or consultation with the trade community which would bear the result of higher import duties, fees and taxes.
At a time when this nation’s businesses are struggling with a sluggish economy and global competition, it is difficult to understand why CBP would propose a rule that would undermine efforts to stimulate the economy by taking action that will impair businesses and raise consumer prices.
I believe this proposed change is substantively wrong and I respectfully request that CBP withdraw it from further consideration. Thank you for your time.
The Situation and ASA’s Position
The U.S. Bureau of Customs and Border Protection (CBP) is proposing an import duty rule regarding “first sale” that will reverse a well-settled practice of customs valuation. This unilateral and arbitrary proposal on the “first sale rule” will undermine nearly 20 years of U.S. Federal Court jurisprudence and raise U.S. consumer prices. It will have a significant negative impact on U.S. companies who have relied on this practice and now may be forced to restructure and revise business models that have been built around this practice of valuation.
This new rule was proposed with no advance notice or consultation with the trade community which would bear the result of higher import duties, fees and taxes.
The American Sportfishing Association’s (ASA) position is that the proposed change is misguided and undermines efforts to stimulate the economy by taking an action that will impair businesses and raise consumer prices. ASA is urging the CBP Bureau to withdraw it from further consideration.
