NCSD Consumer Products and Mass Merchandising Branch has Received 237 Ruling Requests in FY 2024

The National Commodity Specialist Division's consumer products and mass merchandising branch has received 237 ruling requests relating to 312 products so far in FY 2024, Steve Mack, the NCSD's director, said at CBP's NCSD Trade Forum April 3. Seventy-six, or 32%, of the ruling requests were subject to trade remedies, while 64, or 27%, of the ruling requests involve country of origin scenarios, Mack said.

Around 92% of the ruling requests received were through the agency's "e-rulings program," Mack said.

The time it takes to issue a ruling for the consumer products and mass merchandising branch is around 15 days on average, which is ahead of the 30-day standard CBP sets for itself, Mack said. For CTPAT Trade Compliance partners, rulings are to be issued within 20 days, and the branch's current average is 12 days.

The NCSD was reorganized at the end of FY 2023 by creating a new enforcement and trade remedies branch, said Alice Kipel, executive director of CBP's Office of Regulations & Rulings. The new branch was created "splitting off product lines" from the other NCSD branches, and Mark Nackman will serve as branch chief, Kipel said.

The reason for the new branch is that the NCSD has noticed that enforcement-related questions tend to come up more frequently in "certain commodity areas" through meetings with its National Import Specialists, Kipel said. The new branch was added to "further focus" its enforcement efforts, and those working in the branch can develop their expertise in areas such as helping the Commerce Department draft the scope of an antidumping duty order so that the orders are easier to administer by CBP, Kipel said.

This focus does not stray from the NCSD mission as watching out for enforcement issues is "integral" to the department's mission, Kipel said. If the agency is able to better detect and deter violations, that will allow those who classify their products correctly to "benefit from the trade facilitation work" rather than let violators gain an advantage, Kipel said.