CSMS Message: 96-001080

TO : ALL ABI BROKERS.

FROM : MARSHA MALBROUGH

SUBJECT : 97 AUTO PARTS #11

DATE : 12/03/96

7338012
DECEMBER 3, 1996

FILE: FO:TC:C:S DAK

FROM : ASSISTANT COMMISSIONER
OFFICE OF FIELD OPERATIONS

SUBJECT: CERTAIN AUTOMOBILE PARTS: STATISTICAL UNITS OF
QUANTITY TO CHANGE IN JANUARY 1997

THIS MESSAGE WAS ORIGINALLY POSTED ON JULY 8, 1996, AS MESSAGE
#96-0568. IT IS BEING REPOSTED TO REMIND THOSE CONCERNED THAT
THE IMPLEMENTATION DATE (JANUARY 1, 1997) IS NEAR. THIS MESSAGE
HAS BEEN POSTED TO THE USCS BULLETIN BOARD SYSTEM (OTO-5), ABI,
AND TO THE CUSTOMS ELECTRONIC BULLETIN BOARD (CEBB).

ACTION:

AT A MEETING HELD ON MAY 15, 1996, THE COMMITTEE FOR STATISTICAL
ANNOTATION OF TARIFF SCHEDULES (484 COMMITTEE) MADE THE DECISION
TO CHANGE THE UNIT OF QUANTITY TO "NO." FOR THOSE ITEMS IN
SUBHEADING 8708 OF THE HARMONIZED TARIFF SCHEDULE (HTS) FOR WHICH
THE UNIT OF QUANTITY WAS "X" PRIOR TO JANUARY 1, 1995, BUT WHICH
WAS CHANGED TO "KG" ON THAT DATE.

IT WAS AGREED THAT, TO PROVIDE THE TRADE WITH SUFFICIENT TIME TO
PREPARE FOR THIS CHANGE, IMPLEMENTATION WOULD TAKE PLACE ON
JANUARY 1, 1997.

BACKGROUND:

CHAPTER 87 OF THE HARMONIZED TARIFF SCHEDULE (HTS) CHANGED
SIGNIFICANTLY IN JANUARY OF 1995. THE NET QUANTITY UNITS IN
MANY OF THE 10-DIGIT HTS NUMBERS WERE CHANGED FROM "X" TO "KG."
HOWEVER, MANY IMPORTERS AND BROKERS DID NOT REPORT ACCURATE NET
WEIGHTS AFTER THE CHANGE OCCURRED.

ON AUGUST 9, 1995, REPRESENTATIVES OF THE CUSTOMS SERVICE, THE
BUREAU OF THE CENSUS, AND THE INTERNATIONAL TRADE COMMISSION,
SITTING AS THE COMMITTEE FOR STATISTICAL ANNOTATION OF TARIFF
SCHEDULES, MET WITH MEMBERS OF THE AUTOMOBILE INDUSTRY TO DISCUSS
THE IMPLEMENTATION OF THE NEW TARIFF REQUIREMENT. DURING THAT
MEETING, INDUSTRY REPRESENTATIVES STATED THAT LINE ITEM NET
WEIGHT INFORMATION COULD BE PROVIDED IF THEY WERE GIVEN TIME TO
REPROGRAM THEIR COMPUTER SYSTEMS. AN IMPLEMENTATION DATE OF
JANUARY 1, 1996, WAS DETERMINED BY THOSE IN ATTENDANCE TO BE
VIABLE. THE REQUIREMENT WAS IMPLEMENTED ON THAT DATE.

SINCE THAT TIME, ADDITIONAL CONCERNS HAVE BEEN RAISED ABOUT THE
ACCURACY OF THE NET WEIGHTS SUBMITTED, AND THE USEFULNESS OF NET
WEIGHTS AS A UNIT OF QUANTITY FOR AUTOMOBILE PARTS. IN DECEMBER
1995, THE DOMESTIC AUTOMOBILE MANUFACTURERS REQUESTED THAT THE
484 COMMITTEE REVISIT THIS ISSUE. THE CUSTOMS SERVICE HAS
REVIEWED THE USEFULNESS OF THE NET WEIGHT DATA, AND HAS
DETERMINED THAT, IN MOST CASES, THIS INFORMATION IS INSUFFICIENT
TO ACCURATELY TARGET HIGH RISK SHIPMENTS FOR EXAMINATION.

CUSTOMS AND THE BUREAU OF THE CENSUS DETERMINED THAT THE UNIT OF
QUANTITY FOR AUTO PARTS WHICH WOULD PROVE MOST USEFUL FOR THEIR
PURPOSES WAS "NO." (NUMBER). REPRESENTATIVES OF THE DOMESTIC
AUTOMOBILE MANUFACTURERS, CONTACTED INFORMALLY, INDICATED THAT
THEY COULD LIVE WITH "NO." BETTER THAN THEY COULD WITH "KG."

NOTIFICATION:

NOTIFICATION OF THIS CHANGE HAS BEEN PROVIDED TO THE ASSOCIATION
OF INTERNATIONAL AUTOMOBILE MANUFACTURERS, INC., AND THE AMERICAN
AUTOMOBILE MANUFACTURERS ASSOCIATION. THIS MESSAGE IS BEING
POSTED TO THE CUSTOMS ELECTRONIC BULLETIN BOARD, AND IS BEING
SENT AS AN ADMINISTRATIVE MESSAGE TO ALL ABI BROKERS AND
IMPORTERS.

ACCURATE INFORMATION REQUIRED:

THE CUSTOMS SERVICE EXPECTS ALL CONCERNED IMPORTERS AND BROKERS
TO BE PREPARED FOR THIS CHANGE AND TO PRESENT ACCURATE
STATISTICAL DATA. IF ACCURATE INFORMATION IS NOT PROVIDED, THEN,
UNDER THE MODERNIZATION ACT, IMPORTERS MAY BE HELD LIABLE FOR
PENALTIES RESULTING FROM LACK OF REASONABLE CARE.

IF ADDITIONAL INFORMATION ON THIS ISSUE IS REQUIRED, PLEASE
CONTACT MR. DAVID KAHNE, STATISTICS, TRADE COMPLIANCE, AT
(202) 927-0159.

SAMUEL H. BANKS