The Good, The Bad, and The Sticky: Syrups and Honey 2012 Customs Brokers & Forwarders Association Seminar Commodity Team 776 Port of San Francisco Customs And Border Protection OVERVIEW Various Types of Syrups and Blends containing Fructose, Glucose and Maltose Scope/Latest Update on Honey and Syrup Blends from China What information to ask from 1st time honey/syrup importers Q & A Headings 1702-Other sugars, including chemically pure lactose, maltose, glucose and fructose, in solid form; sugar syrups not containing added flavoring or coloring matter; 1702.11-Lactose Syrup 1702.20-Maple Syrup Headings (cont.) 1702.30-Glucose Syrup (No Fructose or contains <20% in dry state) 1702.40-Glucose Syrup (Contains 2049% Fructose in dry state) 1702.60-Fructose Syrup (>50% Fructose) 1702.90-Other Most are subject to Quota What about Brown Rice Syrups? Brown Rice Syrup usually contains maltose, which will put it under 1702.90.9000 as “other sugar and sugar syrup blends: other” Important to ask the importer for ingredient list to determine correct HTS code for the syrups. Honey/Syrup Blends More than 50% natural honey--the blend should be classified as honey (0409.00). Less than 50% natural honey--the blend should be classified as syrups. HTS codes will be determined by % of fructose, glucose and maltose in the syrups. Importer must provide percentage of honey vs syrup to properly classify it. Honey/Rice Syrup Blends from China One of the ways for importers to circumvent antidumping duties. The merchandise is either honey or have some honey drums mixed in with syrup drums in the shipment (to be blended later domestically). Previously subject to Antidumping Duties (A570-863) if honey is >50%. SCOPE SUMMARY UPDATE Effective June 21, 2012 FR V.77, No. 120 ALL honey/syrup blends from China, regardless of the percentage of honey they contain, are now within scope and subject to anti-dumping duty of $2.63/kg. Things to ask from First Time/Suspicious Importers All documents/paperwork in English. Process flowchart, Certificate of Analysis, and Specification Sheet. Be extra careful with first time importers having large and/or multiple honey/syrup shipments within a short period of time. CBP Requests and Actions Suspicious shipments will be sampled and tested. Single Entry Bond Requirements (usually at 3 times the value) before shipment is released. Shipments will be re-exported if no SEB. Purchase Orders and Proof of Payment. Beekeeper Records and Transportation Records. CBP Requests and Actions (cont.) Invoices for the containers (Drums, Barrels). Correspondences (emails, etc.) between Seller and Buyer. Domestic Buyer Information. If the syrup contains honey with Chinese origin, then importer must pay ADD in cash before release or have it re-exported to original country of export. Questions?