CBP Updates its Instructions For Completing the CBP 7501 to Reflect Changes in the Manufacturer ID for Textiles and the AD/CVD Case Number

According to CBP, the changes being made to the instructions involve:

Block 13 - Manufacturer ID

Appendix 2 - Rules for Constructing the Manufacturer Identification Code

Section B of Column 29 - AD/CVD Case Number

Block 13 - Manufacturer ID. CBP has amended its instructions for Block 13 (Manufacturer ID) by adding a new provision relating to textile shipments which states:

"For textile shipments, the manufacturer should be construed to refer to the actual manufacturer in accordance with 19 CFR 102.23(a) and the Appendix to 19 CFR Part 102 - Textile and Apparel Manufacturer ID."

CBP also revised the instructions for Block 13 by adding a provision which states that "non-textile shipments may use the invoicing party or parties (manufacturers or other direct suppliers)."

(This language appears to replace CBP's previous instructions which stated that "for purposes of this code, the manufacturer should be construed to refer to the invoicing party or parties (manufacturers or other direct suppliers). The name and address of the invoicing party, whose invoice accompanies the CBP entry, should be used to construct the MID.")

(See ITT's Online Archives or 10/11/05 news, 05101105, for BP summary of CBP's new requirement of the origin-conferring MID for textiles and apparel.)

Appendix 2 (Rules for Constructing the Manufacturer Identification Code). CBP has amended its rules for constructing the MID in Appendix 2 in order to add the following new paragraph regarding textile and apparel products:

"Pursuant to 19 CFR 102.23(a), all entries of textile or apparel products listed in 19 CFR 102.21(b)(5) must identify on CBP Form 3461 (Entry/Immediate Delivery) and CBP Form 7501 (Entry Summary), and in all electronic data transmissions that require identification of the manufacturer, the manufacturer of such products through a manufacturer identification code (MID) constructed from the name and address of the entity performing the origin-conferring operations."

CBP has also revised some of the language in Appendix 2 and has reformatted Appendix 2 into more of an outline format.

Column 29 (AD/CVD Case Number). CBP has revised its instructions for column 29 by adding the following new section:

The application of AD/CV case numbers should follow this hierarchy:

If the exporter has its own rate, use the case number assigned to the exporter;

If the exporter does not have its own case number, use the case number assigned to the manufacturer/producer; or

If neither the exporter nor the manufacturer/producer has its own case number, use the "all others" case number with a suffix of 000 (ex. A-000-000-000).

(This new section replaces the paragraph in CBP's August 2005 instructions for Column 29 which stated that "if the actual manufacturer of the goods is not known, the suffix of 999 (ex. A-000-000-999) must be used to indicate that the actual manufacturer is not known. The case numbers with a suffix of 000 (ex. A-000-000-000) should only be used when the identity of the manufacturer is known and falls under the other provisions of the AD/CVD case.")

(Subscribers should note that the estimated AD/CV rate at which AD/CV merchandise is entered is not necessarily the AD/CV rate at which it liquidates. See ITT's Online Archives or 03/10/06 news, 06031015, for BP summary of International Trade Administration (ITA) notice regarding liquidation for resellers of market economy country AD products.)

CBP contact - Bruce Coulliette (202) 344-2148

CBP memo and revised instructions (dated 03/23/06) available at http://www.cbp.gov/linkhandler/cgov/import/cargo_summary/cbp7501/7501_instruction.ctt/7501_instruction.doc.