Thomas J. Russo
Metals & Machinery Branch Chief
National Commodity Specialist
Division (NCSD)- New York
NATIONAL COMMODITY SPECIALIST DIVISION
(NCSD)
 The NCSD is located at 1 Penn Plaza (previously 6 WTC) in
New York and is composed of 48 National Import Specialists
(NISs) and 45 National Import Specialist Assistants (NISAs)
 The NISs are the recognized Commodity and Harmonized Tariff
Classification experts in CBP
 The NISs area of responsibility is defined and assigned by HTS
number
 The NCSD is a Division of the Regulations and Rulings (R&R)
located in Washington D.C.
 R&R is under the new Office of International Trade (OT)
National Commodity Specialist Division
(NCSD)
Division Director
Branch 1
Metals & Machinery
Electronics
Heavy Machinery
Steel
Branch 2
Special Products
Chemicals
Food
Wood
Branch 3
Textiles & Apparel
Wearing Apparel
Fibers & Fabric
Luggage
National Commodity Specialist Division (NCSD)
Major Functions to Achieve National Uniformity
and Informed Compliance
 Technical advice to Headquarters and Other
Government Offices/Agencies
 Information/Advice to Field Offices
 Risk Assessment/Database Maintenance
 Advice to the Public
Technical advice to Headquarters and other
government offices/agencies
 CIT/Assistant Chief Counsel/Department of Justice case
preparation, stipulations
 International Agreements Staff – HQ – Review and comment
on draft agenda matters before the HSC of the WCO
 ITC – US Tariff language, new provisions, etc.
 Commerce Department - AD/CVD scope determinations,
new statistical breakouts
Information/Advice to Field Offices
 Responding to internal electronic HTS classification
questions from ports
 Issuing internal electronic Alerts on HTS changes/issues
 National Commodity Training Sessions (seminar program)
 Mini-seminars/port visits – address issues specific to a
port or group of ports
 Email network messages or telephone contacts
 Responses to Focused Assessment Team inquiries
Advice to the Public
 Issue Binding Rulings – Classification, free trade
agreements, country of origin, marking
 Informed Compliance Publications
 Informed Compliance Seminars, Commodity Specific
Training Sessions
 Presentations to trade associations – e.g., LIIEA, AAEI,
American Footwear Assoc., etc.
 Telephone advice – urgent or unusual issues, especially
admissibility
Binding Rulings
Authority 19 C.F.R. 177
Basic Requirements
 Name, address, email address, of requesting party
 Description of transaction - Prospective v. Current
 Statements – No issues pending
 Complete description of goods in imported condition
 Type of Ruling Request (e.g. Classification etc.)
Types of Rulings
 Classification
 Marking
 Country of Origin
 Free Trade agreements
eRulings program
 Via email since 2003
 eRulings Template created in December 2005
 Found on CBP.gov
 Fill in the blanks
 Attach Pictures, Illustrations, Manuals
 Electronic signature
 Electronic Ruling Program eliminates mailing on both ends to
reduce overall processing time and expedite receipt of
decisions.
 EXCEPTION - No samples permitted
BY THE NUMBERS
 A total of over 9000 binding ruling requests were filed in FY
2007.
 Over 25% or approximately 2,400 requests were eRulings.
 Over 2000 ( 225 per month) since the start of the new web
template in December of 2005.
 Average response time is approximately 20 days.
KEY BINDING RULING CBP WEBSITES
 CBP Main Site - http://www.cbp.gov/
 What are Rulings
 http://www.cbp.gov/xp/cgov/toolbox/legal/Rulings/ruling_letters.x
ml
 eRulings Requirements
http://www.cbp.gov/xp/cgov/toolbox/legal/Rulings/eRulingRequire
ments.xml
 eRulings Template
 https://apps.cbp.gov/erulings/index.asp
 Customs Rulings Online Search Systems - CROSS
http://rulings.cbp.dhs.gov/