Kanon Blog

Section 301 was the first Chapter 99 overlay and remains the largest single driver of Chinese-origin duty liability. The trigger is a substantial-transformation origin test, not the shipping route — and most of the recoverable money sits in an opt-in exclusion layer nobody automatically applies. Part 2 of an 8-part series on Chapter 99.

A CBP Focused Assessment doesn't punish every classification error — it punishes the absence of reasonable care. Here's how the audit actually works, and what separates a duty bill from a penalty.

Chapters 1–97 classify products. Chapter 99 classifies policy — and it's bolted onto the HTSUS with different rules, a different update cadence, and a different failure mode. Part 1 of an 8-part series on Chapter 99.

The First Sale Rule isn't a discount — it's a choice about which sale in a multi-tiered transaction is the legally correct one to value under 19 U.S.C. § 1401a, and CBP tests that choice hard.

Country of origin isn't the country on the shipping label — it's the country of last substantial transformation, and the test changes depending on whether you're asking about duty, marking, or FTA eligibility.

Two customs brokers can each follow the GRI in good faith and land on different HTS codes for the same product — not from carelessness, but because neither traversal was ever recorded.

USITC updates the HTSUS at least once a year, and the update doesn't just add provisions — it can silently invalidate classifications made under the prior version. Here's what actually changes and why version tracking matters.

The six GRIs govern every HTS classification and must be applied in strict order. Here's what each rule actually does, in plain English, and why skipping the order is the most common way a classification gets successfully challenged.

A USTR Section 301 exclusion only helps if it's actively claimed with the right Chapter 99 code, tracked through Federal Register notices, and caught before the protest window closes. Most importers miss at least one of the three.

Prior disclosure and a CBP protest both fix a classification error, but they're not interchangeable — one closes the moment CBP issues a CF-29, and most importers don't realize it until it's already too late.

GRI 3(b) essential character has no formula on purpose. Here's why that refusal makes it the most contested standard in HTS classification — and what a defensible determination actually requires.