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The Simple IEEPA Refund Checklist for Importers

 Many importers are now asking the same question: “Do I qualify for an IEEPA tariff refund?” The answer depends on your customs records, but the first step is simple: review your import paperwork. Importers should not wait until the last minute. Even if you are not ready to file anything today, you should start organizing the information your broker may need. Here is a simple checklist: 1. Confirm whether your company paid IEEPA-related duties. 2. Find the affected entry numbers. 3. Confirm who was listed as the importer of record. 4. Contact the customs broker that filed the entries. 5. Check whether your company has ACE Portal access. 6. Make sure bank/refund information is current. 7. Separate open, liquidated, protested, or older entries. 8. Ask your broker whether the entries may qualify under the current CAPE process. The important point is this: You do not need to understand every legal detail before taking action. You just need to start with your paperwork. For apparel and ...

Why Importers Should Review Their IEEPA Tariff Refunds Now

Many U.S. importers paid additional tariffs under IEEPA-related tariff programs. Now that refund processing has started, importers should review whether their past entries may qualify for a refund. This does not mean every company automatically receives money back the same way. Eligibility depends on the importer of record, the entry history, payment records, liquidation status, and whether the correct process is followed. But many importers may be surprised by one thing: The refund process may be more accessible than they think. In many cases, the first step is not complicated. Importers should gather their customs entry information and speak with their customs broker to review whether IEEPA duties were paid on eligible entries. Importers should check: Were IEEPA-related duties paid? Which entries were affected? Who was listed as the importer of record? Does the importer have ACE Portal access? Is bank information properly set up for electronic refunds? Is the original cus...

MoCRA Is Not FDA Approval: What Cosmetic Importers Should Know

Cosmetic importers should be careful when a supplier says: “This product is FDA approved.” For most cosmetics, that statement can be misleading. Under MoCRA, many cosmetic facilities must register with FDA, and responsible persons must list marketed cosmetic products with FDA when required. But registration and listing are not the same thing as FDA approval. This is an important difference. A supplier may have a facility registration. A product may have a listing. But that does not mean FDA reviewed the product and approved it like a drug. Importers should be careful with marketing language, supplier documents, and certificates that make the product sound officially approved. Before importing cosmetics, ask: 1. Is this a cosmetic, drug, or both? 2. Are there SPF, acne, whitening, anti-aging, hair growth, pain relief, or medical claims? 3. Is the supplier saying “FDA approved” when they only mean registered or listed? 4. Who is the responsible person on the label? 5. Has the product bee...

Why K-Beauty Importers Should Ask for the Manufacturer FEI

Before importing K-beauty products into the United States, one question should be asked early: Does the manufacturer have an FEI? FEI means FDA Establishment Identifier. It is an identifying number used by FDA for facilities. Under MoCRA, many cosmetic product facilities must register with FDA. FDA has stated that it intends to use the FEI as the required facility registration number. For importers, this matters because the FEI can help confirm that the supplier is prepared for the U.S. market. This does not mean the importer should blindly accept any number from a supplier. Importers should ask: 1. What is the manufacturer’s legal facility name? 2. What is the physical manufacturing address? 3. Does the facility have an FEI? 4. Has the facility completed FDA cosmetic facility registration if required? 5. When is the facility registration renewal date? 6. Does the supplier understand U.S. cosmetic product listing requirements? 7. Who is responsible for the product listing and label inf...

What K-Beauty Importers Should Know About MoCRA

 K-beauty is growing fast in the U.S., but importing cosmetics is not the same as importing regular general merchandise. One of the biggest changes importers need to understand is MoCRA. MoCRA stands for the Modernization of Cosmetics Regulation Act. It expanded FDA oversight of cosmetics and created new compliance responsibilities for the cosmetics industry. For importers, the main point is simple: Do not treat cosmetics like ordinary cargo. Before a K-beauty shipment moves, importers should ask basic questions: 1. Is the Korean manufacturer registered with FDA if registration is required? 2. Does the facility have an FDA Establishment Identifier, also called an FEI? 3. Has the cosmetic product been listed with FDA if listing is required? 4. Who is the “responsible person” listed on the product label? 5. Are the ingredients properly documented? 6. Are labels and product claims being reviewed? 7. Does the broker have enough information before entry? This matters because a shipment ...