IMAG Submits Comments to CBP

In comments to U.S. Customs and Border Protection (CBP) on two recent proposed rules, IMAG encouraged the agency to use data in conjunction with emerging technologies and to retain a de minimis threshold for all Section 321 shipments.

IMAG acknowledged the importance of providing accurate advance data elements so that CBP can ensure the security of all import channels, prevent prohibited goods and counterfeits from entering the country, and protect intellectual property rights. Before collecting additional data, however, IMAG encouraged CBP to maximize its use of current data, coupled with the expanded use of artificial intelligence and machine learning technologies. IMAG also strongly urged retention of a de minimis threshold for all Section 321 shipments, including those subject to Section 301, 201, or 232 tariffs (as well as tariffs issued under other legal authorities), noting the enormous economic harm to small businesses and consumers.

IMAG also stressed the importance of sufficient time for businesses to implement changes given the disruption that occurs when new rules are initiated with no lead time.