Don’t Give Customs an Excuse to Ask a Question—Part 2!

On April 1, 2024, Customs and Border Protection (CBP) released a new Cargo Systems Messaging Service announcement addressing “vague descriptions” of imported merchandise. 

The CSMS reminded importers of the importance of using a complete verbal description, in English, with sufficient detail.  

On April 11, 2024, Customs and Border Protection (CBP) released a new CSMS: “# 60144714 – Update on Vague Merchandise Description Cargo Messages.”  The CSMS specifically addresses forwarders filing descriptions of the goods on the manifest, and specifically calls out the modes of transportation for vessel, air, rail, truck, and express consignments.

CBP is specifically concerned with the descriptions used on House Bills. 

Let’s summarize: the description on an invoice must be sufficient for accurate determination of duty; in other words, sufficient for accurate tariff classification.  

From the CMSM: “Entry filers…should also be advised that…the entry transaction, which has a 10-digit…(HTSUS) classification, is associated with a bill that included an unacceptably vague cargo description. The entry filer is required to demonstrate upon request how the classification was determined (emphasis added).”

After all, what is the tariff classification “daily necessities?”  Can we at least agree on the basics of 1905.90.9090, 2201.90.0000 and 2804.40.0000?  

Customs has taken it one step further and published a list of unacceptably vague descriptions: 

My favorite vague descriptions are, in ascending order:

4. Thing

3. Stuff

2. Company business

And my #1 favorite vague description is:

1. Powder

Let’s remember the goal of using a verbal description: we want the customs agent to look at the description, look at the HTS classification, and think “Yes, that makes sense.”  We do not want to give an agent an opportunity to ask a question.

O’Meara and Associates, Inc. has extensive experience writing customs-friendly descriptions used for import and export declarations.  We routinely classify thousands of SKUs per year and have classified master catalogues for more than a few clients.

When we at O’Meara and Associates, Inc. do an import audit for a client, when we examine (or reexamine) an importer’s HTS classifications, the first things we look at are classifications whose descriptors begin with a basket provision.  CBP takes the same approach.  You should too.