CSMS Message: 98-000592

TO : ALL ABI BROKERS.

FROM : CARLA ZZ-DONOFRIO

SUBJECT : REVISED PREIMPORTATION PROGRAM

DATE : 07/15/1998

REVISION OF THE PRE-IMPORTATION REVIEW PROGRAM
SUMMARY

THIS NOTICE OUTLINES AND INVITES COMMENTS CONCERNING CUSTOMS
PLANS TO REVISE THE EXISTING PRE-IMPORTATION REVIEW PROGRAM
(PIRP.) IN RESTRUCTURING THE PIRP, CUSTOMS SEEKS TO ENSURE
PROGRAM POLICIES AND PROCEDURES ARE CONSISTENT WITH:

1) CUSTOMS AND IMPORTER RESPONSIBILITIES ESTABLISHED BY THE CUSTOMS
MODERNIZATION ACT; AND
2) OTHER AGENCY PROGRAMS IN WHICH CUSTOMS WORKS WITH MEMBERS
OF THE IMPORTING COMMUNITY TO PROMOTE IMPORT COMPLIANCE.

WRITTEN COMMENTS MAY BE SUBMITTED TO: PAUL K.SCHWARTZ, DIRECTOR,
IMPORT OPERATIONS; U.S. CUSTOMS SERVICE; 1300PENNSYLVANIA AVENUE,
ROOM 5.2.A.; WASHINGTON, D.C. 20229. COMMENTS MUST BE SUBMITTED
NO LATER THAN TUESDAY, SEPTEMBER 15, 1998.

BACKGROUND:

THE PRE-ENTRY CLASSIFICATION PROGRAM WAS IMPLEMENTED IN 1989.
ITS OBJECTIVE WAS TO INCREASE CONTACT BETWEEN CUSTOMS AND
IMPORTERS PRIOR TO IMPORTATION. PRE-IMPORTATION CONTACT PROVIDED
A MEANS TO DISCUSS AND-OR RESOLVE TARIFF CLASSIFICATION AND OTHER
IMPORT RELATED ISSUES PRIOR TO IMPORTATION. ALTHOUGH RENDERING
CLASSIFICATION ADVICE TO IMPORTERS WAS NOT NEW, THE PRE-ENTRY
CLASSIFICATION PROGRAM PROVIDED A FORMAL PROCESS WHICH ENABLED
IMPORTERS TO REVIEW MERCHANDISE CLASSIFICATIONS WITH A CUSTOMS
IMPORT SPECIALIST, AND TO OBTAIN A BINDING CLASSIFICATION RULING
COVERING THE SPECIFIC MERCHANDISE REVIEWED.

IN 1991, CUSTOMS IMPLEMENTED THE PRE-IMPORTATION REVIEW PROGRAM
(PIRP). THE PIRP INCORPORATED THE PRECLASSIFICATION REVIEW
PROCEDURES OF THE PRE-ENTRY CLASSIFICATION PROGRAM WHILE
ESTABLISHING NEW PRE-APPROVAL PROCEDURES FOR LARGER IMPORTERS
WHO, DUE TO VOLUMINOUS IMPORT INVENTORIES, WERE OFTEN EXCLUDED
FROM THE PRE-ENTRY CLASSIFICATION PROGRAM. UNDER THE PIRP,
IMPORTERS COULD REQUEST EITHER A BINDING PRE-ENTRY CLASSIFICATION
REVIEW (COVERING SPECIFIC ITEMS) OR A NON-BINDING PRE-APPROVAL
REVIEW (COVERING A REPRESENTATIVE SAMPLE OF THE IMPORTER'S
MERCHANDISE INVENTORY.) A PRE-APPROVAL REVIEW INVOLVED A
SYSTEMATIC EVALUATION OF AN IMPORTER'S PROCEDURES OR PROCESS FOR
CLASSIFYING ITS MERCHANDISE RATHER THAN AN ACTUAL REVIEW OF EACH
ITEM. WHEREAS PRE-ENTRY CLASSIFICATION REVIEWS RESULTED IN
BINDING RULINGS COVERING SPECIFIC MERCHANDISE, PRE-APPROVAL
REVIEWS RESULTED IN THE APPROVAL OF THE IMPORTER'S PROCESS OR
SYSTEM FOR CLASSIFYING ITS MERCHANDISE.

WITH IMPORT ACTIVITY CONTINUING TO INCREASE, CUSTOMS BEGAN TO
IMPLEMENT OPERATIONAL PROCEDURES (E.G., COMPLIANCE MEASUREMENT)
WHICH EMPHASIZED SAMPLING AND GREATER SELECTIVITY WITH REGARD TO
CARGO EXAMINATIONS AND ENTRY SUMMARY REVIEWS. GREATER
SELECTIVITY, COMBINED WITH LESS REVIEW OF INDIVIDUAL IMPORT
TRANSACTIONS, EXTENDED MANY OF THE BENEFITS ASSOCIATED WITH
PARTICIPATION IN THE PIRP (E.G., FEWER EXAMINATIONS, EXPEDITED
CARGO RELEASE, FEWER REQUESTS FOR SUPPLEMENTAL INFORMATION) TO
ALL IMPORTERS. AS A RESULT, IMPORTER INTEREST IN THE PIRP
DECLINED AND CUSTOMS ELIMINATED THE PIRP PRE-APPROVAL OPTION IN
DECEMBER 1996. ALTHOUGH CUSTOMS CONTINUES TO CONDUCT ENTRY AND
POST-ENTRY REVIEWS OF INDIVIDUAL IMPORT TRANSACTIONS, CARGO AND
IMPORT TRANSACTIONS NOT SPECIFICALLY TARGETED FOR EXAMINATION ARE
IN EFFECT PRE-APPROVED.

SUPPLEMENTAL INFORMATION:

ON DECEMBER 8, 1993, TITLE VI OF THE NORTH AMERICAN FREE TRADE
AGREEMENT IMPLEMENTATION ACT (PUB. L. 103-182, 107 STAT. 2057),
ALSO KNOWN AS THE CUSTOMS MODERNIZATION ACT OR "MOD ACT," BECAME
EFFECTIVE. UNDER THE "MOD ACT" MEMBERS OF THE TRADE COMMUNITY
AND THE CUSTOMS SERVICE SHARE RESPONSIBILITY FOR ENSURING
COMPLIANCE WITH IMPORT REQUIREMENTS. TWO CONCEPTS WHICH EMERGED
FROM THE "MOD ACT" WERE "INFORMED COMPLIANCE" AND "SHARED
RESPONSIBILITY." THE IMPORTER OF RECORD IS RESPONSIBLE FOR USING
"REASONABLE CARE" TO ENTER, CLASSIFY AND VALUE IMPORTED
MERCHANDISE. CUSTOMS IS RESPONSIBLE FOR PROVIDING INFORMATION TO
INFORM AND ASSIST IMPORTERS TO UNDERSTAND AND MEET THEIR IMPORT
OBLIGATIONS, AND IS RESPONSIBLE FOR "FIXING" THE FINAL
CLASSIFICATION AND VALUE OF IMPORTED MERCHANDISE.

IN SEEKING TO PROMOTE INFORMED COMPLIANCE, CUSTOMS HAS SOUGHT TO
PROVIDE IMPORTERS WITH INFORMATION TO ASSIST THEM TO MEET THEIR
IMPORT-RELATED OBLIGATIONS. A SERIES OF INFORMED COMPLIANCE
PUBLICATIONS PROVIDES INFORMATION ON VARIOUS IMPORT RELATED
ISSUES, INCLUDING VALUATION AND TARIFF CLASSIFICATION (INCLUDING
GENERAL GUIDELINES PERTINENT TO PARTICULAR TYPES OF MERCHANDISE.)

THESE PUBLICATIONS, TOGETHER WITH SEMINARS, INCREASED ACCESS TO
CUSTOMS RULINGS, AND OTHER OUTREACH EFFORTS PROVIDE INFORMATION
TO IMPORTERS WHICH MAY BE USED TO AVOID COMPLIANCE PROBLEMS.
IMPORTERS MAY ALSO REQUEST SPECIFIC CLASSIFICATION (OR OTHER
IMPORT-RELATED) RULINGS FROM CUSTOMS IN ACCORDANCE WITH PART 177
OF THE CUSTOMS REGULATIONS. BEYOND THE INFORMATION AND GUIDANCE
AVAILABLE FROM CUSTOMS, MANY IMPORTERS MAINTAIN IN-HOUSE CUSTOMS
STAFFS AND-OR UTILIZE THE SERVICES OF CUSTOMS BROKERS, ATTORNEYS
OR OTHER CONSULTANTS WHO SPECIALIZE IN CUSTOMS AND IMPORT MATTERS
TO ASSIST THEM TO MEET THEIR "REASONABLE CARE" RESPONSIBILITIES.
PROGRAM OBJECTIVE:

WITH CUSTOMS EMPHASIS ON SELECTIVE TRANSACTION VERIFICATIONS,
IMPORTERS WHO ESTABLISH INTERNAL SYSTEMS AND PROCEDURES WHICH
PROMOTE CONSISTENT CLASSIFICATION ACCURACY (AT ALL PORTS) AND
MAINTAIN HIGH COMPLIANCE LEVELS WILL GENERALLY BE SUBJECT TO
FEWER CUSTOMS COMPLIANCE EXAMINATIONS. THROUGH THE REVISED PIRP,
CUSTOMS IMPORT SPECIALISTS WILL WORK WITH INDIVIDUAL IMPORTERS
(AND THEIR AGENTS) TO FURTHER INFORMED COMPLIANCE, PARTICULARLY
IN TARIFF CLASSIFICATION. THE PRIMARY OBJECTIVE OF A PRE-
IMPORTATION REVIEW WILL BE TO EDUCATE, INFORM AND PROVIDE
GUIDANCE TO INDIVIDUAL IMPORTERS PERTINENT TO THE CLASS AND TYPE
OF MERCHANDISE ENTERED BY THE IMPORTER. WHEREAS THE FOCUS OF
PREVIOUS PROGRAM EFFORTS WERE OFTEN ON THE CUSTOMS CLASSIFICATION
RULING WHICH RESULTED FROM A PRE-IMPORTATION REVIEW, THE FOCUS OF
A REVISED PIRP REVIEW WILL BE ON PROVIDING IMPORTERS GUIDANCE
INTENDED TO ENHANCE THEIR CLASSIFICATION UNDERSTANDING AND
CAPABILITY FOR ACCURATELY DETERMINING FUTURE CLASSIFICATIONS.
IT IS NOT INTENDED THAT THE PIRP BE VIEWED BY IMPORTERS AS A
CLASSIFICATION SERVICE OR AS AN ALTERNATIVE TO DEVELOPING AN
INTERNAL CLASSIFICATION CAPABILITY SYSTEM.

PROGRAM OVERVIEW:

CONSISTENT WITH "MOD ACT" THEMES AND RESPONSIBILITIES, REVISED
PRE-IMPORTATION REVIEW PROCEDURES WILL EMPHASIZE THE IMPORTER'S
RESPONSIBILITY FOR DETERMINING PRODUCT CLASSIFICATIONS (WHETHER
IN-HOUSE OR THROUGH THE USE OF CUSTOMS BROKERS OR OTHER CUSTOMS
EXPERTS.) REVIEWS WILL BE CONDUCTED IN PARTNERSHIP WITH
IMPORTERS. ACTIVE PARTICIPATION BY THE IMPORTER WILL FACILITATE
AGREEMENT ON THE CLASSIFICATION OF PARTICULAR ITEMS REVIEWED
DURING THE PRE-IMPORTATION REVIEW (INCLUDING SITUATIONS IN WHICH
THE IMPORTER AND CUSTOMS DISAGREE ON A PARTICULAR PRODUCT
CLASSIFICATION) AND UNDERSTANDING OF THE CLASSIFICATION
PRINCIPLES APPLICABLE TO SIMILAR ITEMS THE IMPORTER EXPECTS TO
IMPORT IN THE FUTURE.

EMPHASIS DURING A PRE-IMPORTATION REVIEW WILL BE PLACED ON THE
SPECIFIC CLASSIFICATION PRINCIPLES, LEGAL NOTES, PRECEDENTS
AND-OR RULINGS APPLICABLE TO THE CLASSIFICATION OF MERCHANDISE
COMPRISING THE IMPORTER'S PRODUCT LINE(S.) IN A SINGLE SESSION
OR OVER A SERIES OF SESSIONS, A CUSTOMS IMPORT SPECIALIST(S) WILL
PROVIDE GUIDANCE INTENDED TO ENHANCE AN IMPORTER'S CLASSIFICATION
KNOWLEDGE AND IMPROVE THEIR INTERNAL CLASSIFICATION
CAPABILITY SYSTEM. ALTHOUGH A PRE-IMPORTATION REVIEW WILL
INCLUDE THE REVIEW OF SPECIFIC ITEMS, IT IS NOT INTENDED TO COVER
THE IMPORTER'S ENTIRE INVENTORY. THE SPECIFIC ITEMS TO BE
INCLUDED IN A PRE-IMPORTATION REVIEW SHOULD BE LIMITED. IN
SELECTING SPECIFIC ITEMS, THE IMPORTER SHOULD IDENTIFY THOSE
ITEMS WITH WHICH IT IS HAVING DIFFICULTY INTERPRETING OR APPLYING
CONTROLLING CLASSIFICATION PRINCIPLES. ITEMS OF WHICH THE
IMPORTER IS CONFIDENT OF THE PROPER CLASSIFICATION SHOULD NOT BE
INCLUDED IN THE REVIEW. LIMITING THE NUMBER OF ITEMS WILL ENABLE
THE IMPORTER AND CUSTOMS TO FOCUS ON SPECIFIC CLASSIFICATION
ISSUES OR PROBLEMATIC AREAS, MAKE THE REVIEW MORE MANAGEABLE, AND
SPEED ITS COMPLETION.

PRIOR TO THE PRE-IMPORTATION REVIEW, THE IMPORTER WILL BE
REQUIRED TO PROVIDE A PRODUCT LIST INCLUDING A PROPOSED TARIFF
CLASSIFICATION FOR EACH OF THE SPECIFIC ITEMS TO BE DISCUSSED
DURING THE PRE-IMPORTATION REVIEW. TO FACILITATE THE EXCHANGE OF
INFORMATION BETWEEN THOSE RESPONSIBLE FOR THE CLASSIFICATION OF
THE IMPORTER'S MERCHANDISE AND CUSTOMS, THE IMPORTER MUST ARRANGE
TO HAVE THEIR CLASSIFICATION SPECIALIST (WHETHER IN-HOUSE OR
OUTSIDE AGENT) AVAILABLE TO PARTICIPATE IN THE REVIEW. AS PART
OF THE ACTUAL REVIEW, THE IMPORTER WILL BE REQUIRED TO PROVIDE
PRODUCT SAMPLES, TECHNICAL LITERATURE OR SPECIFICATIONS, AND
OR OTHER MATERIALS NECESSARY TO REVIEW AND DISCUSS THE PROPOSED
TARIFF CLASSIFICATIONS.

THE IMPORTER'S PRODUCT LIST WITH PROPOSED TARIFF CLASSIFICATIONS
WILL PROVIDE THE BASIS FOR THE PRE-IMPORTATION REVIEW. IN
ADDITION TO RECEIVING CLASSIFICATION GUIDANCE APPLICABLE TO THE
CLASS OR TYPE OF MERCHANDISE IMPORTED, EACH OF THE IMPORTER'S
PROPOSED CLASSIFICATIONS WILL BE REVIEWED. PRE-IMPORTATION
REVIEW WILL BE AN OPEN AND TRANSPARENT PROCESS WITH CONTINUING
DISCUSSION BETWEEN THE IMPORTER AND THE CUSTOMS IMPORT
SPECIALIST. WHERE AN IMPORTER'S PROPOSED CLASSIFICATION IS
DETERMINED TO BE INCORRECT, THE IMPORT SPECIALIST WILL REVIEW THE
PROPER CLASSIFICATION AND DISCUSS THE APPLICABLE CLASSIFICATION
PRINCIPLES OR REASONING BEHIND THE PROPER CLASSIFICATION. AS AN
ACTIVE PARTICIPANT IN THE PRE-IMPORTATION REVIEW PROCESS, THE
IMPORTER MAY OFFER REASONING FOR ITS PROPOSED CLASSIFICATION.
THERE MAY BE INSTANCES IN WHICH THE IMPORTER AND CUSTOMS IMPORT
SPECIALIST DISAGREE ON A PARTICULAR CLASSIFICATION(S). THE
NATIONAL COMMODITY SPECIALIST DIVISION (NCSD) WILL PROVIDE
GUIDANCE (AS NEEDED) THROUGHOUT A PRE-IMPORTATION REVIEW,
INCLUDING ASSISTANCE IN RESOLVING DIFFERENCES BETWEEN THE
IMPORTER AND CUSTOMS OVER INDIVIDUAL PRODUCT CLASSIFICATIONS.
IN CONCLUDING A PRE-IMPORTATION REVIEW THE IMPORTER'S PRODUCT
LIST WILL BE REVISED TO REFLECT THE CLASSIFICATION GUIDANCE
PROVIDED RELATIVE TO ANY PROPOSED PRODUCT CLASSIFICATIONS. IN
KEEPING WITH THE "MOD ACT" CONCEPTS OF SHARED RESPONSIBILITY,
INFORMED COMPLIANCE AND REASONABLE CARE, BOTH CUSTOMS AND THE
IMPORTER WILL RETAIN COPIES OF THE FINALIZED ANNOTATED PRODUCT
LISTINGS AND A SUMMARY REPORT DETAILING THE PRE-IMPORTATION
REVIEW. THE ANNOTATED PRODUCT LISTS RESULTING FROM A PRE-
IMPORTATION REVIEW WILL NOT BE REVIEWED BY THE NCSD. HOWEVER, AS
INDICATED ABOVE, THE NCSD WILL, AS NEEDED, PROVIDE GUIDANCE
CONCERNING PARTICULAR PRODUCT CLASSIFICATIONS AND REVIEW THOSE
ITEMS WHERE THE IMPORTER AND CUSTOMS IMPORT SPECIALIST DISAGREE
AS TO THE PROPER CLASSIFICATION.

COPIES OF THE SUMMARY REPORT AND PRODUCT LISTING WITH APPROPRIATE
CLASSIFICATIONS WILL BE DISTRIBUTED TO ALL PORTS IN WHICH THE
IMPORTER ENTERS MERCHANDISE. THE ANNOTATED PRODUCT LISTINGS WILL
HAVE NO LEGAL, BINDING OR PRECEDENTAL EFFECT. IMPORTERS WILL
NOT BE ABLE TO CLAIM DETRIMENTAL RELIANCE IN SUCH INSTANCES WHERE
SUBSEQUENT INFORMATION OR DEVELOPMENTS REVEALS A PARTICULAR ITEM
TO BE MISCLASSIFIED. ALTHOUGH NON-BINDING, THE PRE-IMPORTATION
REVIEW PROCEDURES ESTABLISH A PROCESS INTENDED TO PROVIDE
RELIABLE GUIDANCE. THE SPECIFIC PRODUCT CLASSIFICATIONS REVIEWED
AS PART OF THE PRE-IMPORTATION REVIEW PROCESS WILL BE ACCEPTED BY
CUSTOMS UNLESS FURTHER INFORMATION IS REVEALED, OR OTHER
DEVELOPMENTS (E.G., COURT DECISIONS, RULINGS, CHANGES IN THE
TARIFF SCHEDULE) AFFECT THE GUIDANCE PROVIDED DURING THE PRE-
IMPORTATION REVIEW.

THE EXCEPTION WILL BE FOR MERCHANDISE SUBJECT TO QUOTA-VISA
REQUIREMENTS (E.G., TEXTILES, WEARING APPAREL.) DUE TO CONCERNS
ASSOCIATED WITH ADMISSIBILITY REQUIREMENTS, MERCHANDISE
CLASSIFICATIONS COVERING ITEMS SUBJECT TO QUOTA-VISA REQUIREMENTS
WILL BE SUBJECT TO REVIEW BY THE NCSD AND WILL RESULT IN A
BINDING CLASSIFICATION RULING. ALTHOUGH THE GUIDANCE PROVIDED
BY CUSTOMS MAY APPLY TO SIMILAR ITEMS IMPORTED IN THE FUTURE BY
THE IMPORTER, BINDING CLASSIFICATION STATUS WILL APPLY ONLY THOSE
ITEMS ACTUALLY REVIEWED DURING THE PRE-IMPORTATION REVIEW . THE
IMPORTER'S PRODUCT LIST, AND ANY ACCOMPANYING INFORMATION, WILL
BE FORWARDED TO THE NCSD. FOR ANY PROPOSED TARIFF CLASSIFICATION
DETERMINED TO BE INCORRECT BY THE NCSD, THE APPROPRIATE NIS WILL
INFORM THE IMPORT SPECIALIST WHO CONDUCTED THE PRE-IMPORTATION
REVIEW AND INDICATE THE CORRECT TARIFF CLASSIFICATION. THE
IMPORT SPECIALIST WILL VERBALLY INFORM THE IMPORTER OF THE
CORRECTED TARIFF CLASSIFICATION PRIOR TO ISSUANCE OF THE
PRECLASSIFICATION AS A BINDING RULING (INCLUDING THE CORRECTED
PRODUCT LISTING.) ONCE ISSUED, THE BINDING CLASSIFICATION RULING
WILL BE ACCEPTED BY CUSTOMS UNLESS SUBSEQUENTLY MODIFIED OR
REVOKED BY THE CUSTOMS OFFICE OF REGULATIONS AND RULINGS. SHOULD
SUCH OCCUR, AND THE IMPORTER CAN DEMONSTRATE DETRIMENTAL RELIANCE
ON THE ORIGINAL CLASSIFICATION RULING, THE IMPORTER MAY RECEIVE
UP TO A 90 DAY DEFERRED PERIOD BEFORE THE REVISED CLASSIFICATION
DECISION IS APPLIED.

PARTICIPATION IN THE PIRP:

THE PIRP IS ONE OF SEVERAL PROGRAMS IN WHICH CUSTOMS WILL WORK
WITH IMPORTERS TO PROMOTE ACCURATE TRANSACTION REPORTING AND
ENHANCE COMPLIANCE. UNLIKE THE ACCOUNT MANAGEMENT AND COMPLIANCE
ASSESSMENT PROGRAMS, IN WHICH CUSTOMS SELECTS SPECIFIC IMPORTERS
AND THEIR PARTICIPATION IS MANDATORY, IMPORTER PARTICIPATION IN
PRE-IMPORTATION REVIEW WILL BE VOLUNTARY. ANY IMPORTER,
INCLUDING IMPORTERS WHICH ARE NOT DESIGNATED BY CUSTOMS' AS A
NATIONAL OR PORT ACCOUNT, OR THE SUBJECT OF A COMPLIANCE
ASSESSMENT, MAY REQUEST A PRE-IMPORTATION REVIEW. REQUESTS MAY
BE MADE AT ANY CUSTOMS SERVICE PORT. IMPORTERS WITH PRODUCT
INVENTORIES COVERING SEVERAL CLASSES OF MERCHANDISE WILL BE
REQUIRED TO MAKE A SEPARATE REQUEST FOR EACH CLASS OF MERCHANDISE.
THIS WILL ENABLE THE IMPORTER AND CUSTOMS TO FOCUS ON SPECIFIC
CLASSIFICATION ISSUES AND PRINCIPLES, MAKE THE REVIEW MORE
MANAGEABLE, AND SPEED COMPLETION OF THE REVIEW.

THE ABILITY OF CUSTOMS TO ACCOMMODATE IMPORTER REQUESTS FOR PRE-
IMPORTATION REVIEWS WILL BE LARGELY DETERMINANT UPON THE
AVAILABILITY OF CUSTOMS RESOURCES TO PERFORM THE REVIEW. IT IS
NOT EXPECTED THAT CUSTOMS WILL BE ABLE TO ACCOMMODATE ALL
REQUESTS. WITH LIMITED RESOURCES, CUSTOMS PORTS WILL PRIORITIZE
AND ALLOCATE TIME TO THOSE ACTIVITIES, INCLUDING PRE-IMPORTATION
REVIEWS, THAT OFFER THE GREATEST RETURN TO CUSTOMS. REQUESTS
WILL BE EVALUATED ON A CASE-BY-CASE BASIS WITH CONSIDERATION TO:

- THE IMPORTER'S ANNUAL IMPORT VALUE AND VOLUME
- THE NUMBER OF ITEMS AND TYPE OF MERCHANDISE TO BE REVIEWED
- THE IMPORTER'S COMPLIANCE RATES (NATIONAL-LOCAL)
- THE IMPORTER'S CLASSIFICATION HISTORY (PRIOR CLASSIFICATION
PROBLEMS OR ISSUES)

PRIMARY FOCUS INDUSTRY IMPORTS AND-OR INDUSTRY RANKING

THE NUMBER OF PRE-IMPORTATION REVIEWS AN IMPORTER MAY RECEIVE IN
A GIVEN YEAR (FOR THE SAME CLASS OF MERCHANDISE) WILL BE LIMITED.
FOLLOW-UP PRE-IMPORTATION REVIEWS SHOULD FOCUS ON SPECIFIC
CLASSIFICATION ISSUES, NOT SIMPLY ADDITIONAL STYLES OF THE SAME
TYPE OF MERCHANDISE PREVIOUSLY REVIEWED (AND FOR WHICH
CLASSIFICATION GUIDANCE WAS PROVIDED.) FACTORS WHICH WILL BE
CONSIDERED IN DETERMINING WHETHER TO ACCOMMODATE ADDITIONAL
REQUESTS FOR PRE-IMPORTATION REVIEWS WILL INCLUDE:

- THE SCOPE-ISSUES REVIEWED DURING EACH PREVIOUS PRE-
IMPORTATION REVIEW(S)
- THE GUIDANCE PROVIDED DURING PREVIOUS PRE-IMPORTATION
REVIEW(S)
- SPECIFIC CLASSIFICATION PROBLEMS THE IMPORTER IS HAVING
- THE IMPORTER'S INVENTORY TURNOVER RATE
- THE COMPLEXITY OF MERCHANDISE SUBJECT TO REVIEW