WorkflowTrade Compliance

Tariff Classification

Tariff classification for each new imported part, argued over its own drawing: two HTSUS codes walked rule by rule, a year of duty priced under each, and a challenger before anyone signs.

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Follow one casting's HTSUS code from drawing to sign-off ↓

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The problem

A rough steel casting can pay half its value, or nothing extra, by heading

Engineering releases a change notice, and the item master blocks import orders until the new part has an approved code. The classification analyst works from the drawing, a spec sheet, the tariff and its notes, and the rulings database, and asks the design engineer questions in free-text email. The code goes into the item master; a manager may or may not look.

Since the Section 232 change to full customs value, the heading decides more than the general rate. Yet the runner-up heading is rarely written down, priced or tested before sign-off, the engineer's answer gets paraphrased, and parts from one drawing family drift into two codes that CBP can see across entries.

Built forClassification analystsCustoms counselTrade compliance managersDirectors of global trade

The Problem Today

A new part's code is chosen from a drawing and an engineer's email, and the other heading is rarely written down or priced.

50%: duty on a chapter 73 steel casting's full value, since April published
2×: the lost duties: the negligence penalty cap for a wrong code published

Weighed by hand for each new part

Drawing
Engineer
HTSUS
Rulings

One family, two codesSibling castings coded two ways over the years
The gap priced too lateThe money between two headings shows when CBP asks

The Solution

The drawing's facts markedMaterial, condition, dedicated bore and weight, each wired to a rule
Questions in fixed fieldsEngineering and the foundry fill set fields; notes reach a person
A year priced under each codeGeneral duty and Section 232 at forecast volume, each rate editable
The runner-up argued, then signedA challenger makes the other heading's case; analyst and manager sign

Built-in controls

Nobody approves a code they proposed
A named person reads engineering and supplier notes
Ruling requests need counsel and a second signer

What You Get

Each code is approved with its drawing, its rules and the other heading's best case on file, before the first entry.

Drawing families kept togetherOne decision checked across every sibling casting
A supplier's other parts checkedOne instruction pulls each casting from the same foundry
Earlier rulings beside the choiceThe manager's earlier ruling shown when the question returns

Features

Tariff classification features, from the change notice to the sign-off

The classification analyst and the trade compliance manager use them to code a new imported part before purchasing can order it. The case on these screens: one rough steel valve-body casting.

demoImporter, foundry, people, parts, figures and quoted rulings: all sample data.

01New parts
New and changed parts waiting for an HTSUS code, by due date and status
- Change notices and item master read on arrival. Each new or changed part opens a case the day engineering releases it, in place of a weekly report someone has to notice.
- Candidate headings shown before anyone starts. The analyst sees which parts split between chapters and plans the week around the hard ones.
- Business-day due dates. Each part's target counts business days from release, holidays excluded, so the queue matches what purchasing is waiting for.
02Heading duel
Two HTSUS codes argued side by side over the part's own drawing
- Drawing facts wired to the legal text. Material, as-cast condition, dedicated bore and weight are marked on the drawing and linked to the heading or note they trigger.
- Each candidate with its path, rate and year. Section, chapter, heading and ten digits sit beside what carries each step, so the runner-up is written down from the start.
- Each agent's sources and confidence on its card. A low score on a card tells the analyst which step of the walk to open and test before signing.
03HTSUS path
HTSUS classification walked to the statistical suffix, closed branches kept
- The interpretation rule named at each step. Each level of the path says which rule carries it, so the manager reads the reasoning behind the number.
- Closed branches kept with the reason. A heading ruled out stays on the screen with why, and a branch waiting on engineering stays open until the answer lands.
- The legal text one click away. Heading text and the section and chapter notes open beside the step, from the tariff library.
04Engineering questions
Questions to design engineering answered in fixed fields, not email
- What the part is, never what the code is. The engineer chooses from set answers about use, operation, remaining machining, material and weight, so the answer cannot be paraphrased.
- Answers close or reopen branches. A handwheel would keep the hand-operated branch open; a pneumatic actuator closes it, and the walk updates on its own.
- Free text kept for a person. The analyst reads anything typed outside the fields; no agent compares it.
05Steer
Every casting from the same foundry pulled into the check by one instruction
- A typed steer grows the plan by one step. The analyst widens the run mid-way, and the new step is logged under the analyst's name, with the time.
- The supplier's other castings read against their drawings. Parts coded the way their drawings read pass; the rest come back flagged for the analyst.
- Proposal blocked until each point is handled. The analyst cannot propose while a challenger point has no cited answer and no named person.
06Rival heading
A challenger argues the runner-up heading before anyone proposes a code
- The other heading's strongest case, point by point. The analyst meets the argument a CBP reviewer would make while the code can still change.
- Each point routed by who can close it. Facts go back to the agents, judgments to the analyst, money and policy to the manager, outside questions to the supplier.
- Section 232 exposure raised as its own point. A Section 232 line the rate table assumes at zero is priced as an open question, and the manager decides who confirms it before the first entry.
07Own error
A branch the agents' own HTSUS walk skipped, caught and corrected
- Agents' work challenged like anyone's. A skipped statistical suffix is caught before the analyst signs a code that rests on it.
- The correction shown, not hidden. The walk records the error, the branch it closed and why the code still stands, for the manager to read.
- Each closed branch with its reason. Pipe fittings, complete valves, hand-operated parts and transmission valves each show why they were ruled out, so the manager can test the exclusions.
08Year what-if
A year of duty and Section 232 priced under each candidate code
- General duty and Section 232 at forecast volume. The gap between headings is known before sign-off, at the volume purchasing plans to buy.
- Each rate editable, with its source. Assumed rates carry a label for the analyst to check, so nobody mistakes the rehearsal for a duty bill.
- A ruling threshold on the gap. Above the setting, the approved code goes to counsel and the director for a binding ruling request.
09Drawing family
Sibling parts in the drawing family found coded two ways in the parts master
- Each sibling with its code today and drawing use. The inconsistency CBP could see across entries is visible to the analyst first.
- What the split costs a year. Duty and Section 232 on the siblings under each code sit beside the list, so the manager sees what the inconsistency costs.
- Re-checks only after a rule is approved. The decision on this part becomes a proposed rule; siblings are queued for re-check once a second person approves it.

Who owns HTS classification at the importer, from analyst to counsel

The analyst proposes, the manager checks, and counsel and the director sign anything sent to CBP.

Classification analysts

Propose each new part's HTSUS code and sign it as preparer

The drawing's facts linked to the tariff text
Engineering's answers in fields, not email
The runner-up's case before proposing

Trade compliance managers

Check each proposed code and decide points handed to them

Sign blocked until they open the drawing themselves
Their earlier rulings beside the next case
A year of duty under each code

Customs counsel

Sign binding ruling requests as a legal position

A request drafted with the other side's case
Their own notes left off the request
Open questions on the annex listed

Directors of global trade

Sign ruling requests second, release holds, approve rules and settings

Drawing-family exposure in one place
No rule in force before they approve it
The ruling threshold under their control

More screens

The questions out, the document library, the rules kept and the sign-off chain

Around the duel: what was asked outside, what was read, and who signs in what order.

Questions out: five fixed-field questions to design engineering and four to the foundry, each with its due date, all waiting — **Questions out**Five fixed fields to design engineering and four to the foundry, each showing whether its answer changes the case.

Document library for the casting: drawings and change notice, spec sheet, foundry quotation, HTSUS chapters 73 and 84, CBP guidance, sample rulings and rule M-07 — **Drawing and documents**The drawings and change notice, the spec sheet and quotation, the tariff text, CBP guidance and the rulings library, each labeled by where it lives.

Rules kept: M-07 on rough castings made to one valve model's drawing, M-04 on facts the drawing does not show, M-09 on supplier free text — **Rules the agents keep**Three rules learned from people's rulings, each approved by a person other than its author, with the ruling it came from.

Sign-off screen: preparer and checker in order, the $250,000.00 a year ruling threshold, and no binding ruling request drafted yet — **Who signs, in order**Preparer, then a checker who opens the drawing and both columns. Above the gap setting, a ruling request follows for counsel and the director.

demoSample data, from the working solution.

Four signatures, and a design engineer who answers but never codes

Each signer opens what they sign; nobody checks their own work.

Classification analyst

Sees: The drawing, both candidate paths, the challenger's points and engineering's answers
Signs: The proposed code as preparer, with the rule and the cited facts that carry it

Trade compliance manager

Sees: The drawing and the rulings on both sides, opened personally before signing is possible
Signs: The code as checker, and any point handed up, such as who confirms a Section 232 line

Design engineer

Sees: Questions about what the part is, and any supplier offer that would change it
Signs: Answers in fixed fields, and the decision on that offer; never the code

Customs counsel

Sees: The binding ruling request with the other heading's case stated fairly
Signs: The request as a legal position; counsel's own notes are excluded as privileged

Director of global trade

Sees: The same request after counsel, and the drawing family's exposure
Signs: The request as second person before it is submitted, and any rule the agents learn

Eight agents read, walk and price, and none of them calls a code correct

They prepare the argument; the importer's people make the call.

Intake reader

Reads change notices and the item master and opens a case per new or changed part.

Leaves the choice of owner to a person

Drawing reader

Marks the facts that classify: material, condition, dedicated bore pattern, weight.

Never guesses a fact the drawing does not show

Tree walker

Walks each candidate from section to statistical suffix, naming the rule, and closes branches with reasons.

Never calls a code correct

Rulings researcher

Finds rulings for and against and the rules kept, and drafts the ruling request.

Cites no ruling it cannot show in full

Spec questions

Sends fixed-field questions to engineering and suppliers and reads what comes back in fields and files.

Takes no typed note as a fact

Duty rehearsal

Prices a year under each code with editable rates.

Never treats an assumed rate as a fact

Parts master keeper

Checks the drawing family and the supplier's other parts, and proposes rules.

Changes nothing in the parts master
No rule without a second approver

Rival heading

Builds the strongest case for the runner-up code, the agents' own walk included.

Lets no point pass unanswered or unassigned

Questions importers ask about tariff classification

What is tariff classification?

Tariff classification is choosing the HTSUS code an imported product is entered under, by the general rules of interpretation, the section and chapter notes and CBP rulings. The code sets the general duty and, for steel and aluminum articles, Section 232. Here agents argue the two strongest codes over the part's drawing, and the importer's people sign the code.

How is HTS classification different from HS code classification?

The HS code is the international six-digit base. The HTSUS adds United States subheadings and a statistical suffix to reach ten digits, and those last digits can decide the rate and whether a Section 232 annex line applies.

Who is responsible for the code, the importer or the broker?

The importer of record, who must use reasonable care to classify. The broker files the code the importer approves. Here the importer's analyst proposes, its manager checks, and the broker sees the approved code and any ruling pending.

Is an unfinished casting classified as the finished part?

Under the rule for incomplete or unfinished articles, a blank that already has the character of the finished article can be classified as that article. Whether a given casting does is the importer's call, and the challenger makes the opposite case first.

When should we ask CBP for a binding ruling?

Here, when the money between the two codes passes a threshold the director sets. Counsel signs the request as a legal position, the director adds the second signature, and the request states the condition of the part as imported.

Does AI HTS classification replace the analyst?

No. The agents read, walk the tariff and price, but none of them calls a code correct, and a proposal waits until each challenger point has a cited answer or a named person. The analyst proposes and a manager who did not prepare it approves.

Trade Compliance