As a result of this new administrative ruling, fulfillment centers and domestic warehouses are now recognized as the “one person” for any goods that have not been sold to a specific consumer at the time of importation; consequently those shipments now become eligible for Section 321 provisions.

HOWEVER, we urge everyone to please keep in mind that if the AWB only shows Amazon as the consignee, CBP will flag other shipments consigned to the same person and consider the aggregate value as a violation of Sec 321 if the value exceeds the $800 limit, or if CBP determines it is necessary to protect the revenue or national interest.

THEREFORE, we highly recommend to all importers to provide the first and last name of the owner or purchaser or the name of the business.

Another positive impact of this ruling certainly becomes the fact that CBP is automatically provided with foreign seller information, which will help them target and interdict counterfeit products, consumer safety violations, and any other threats before the goods are about to enter the U.S.


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