This article came about because in the course of communicating with a long time friend and experienced and certified trade professional we found a major trailer manufacturer who didn’t know what assists are!
We continue to reference ‘assists’ on every importer meeting as most people don’t appreciate/comprehend the implication. Let’s face it ‘in Canada we all think of assists as something related to reward for the person passing the puck to the goal scorer’
Seriously though any input to the manufacturing process that an importer provides is to be included in the value of the goods. Most common references relate to tools, die’s, etc. that are provided to a manufacture in order to make a part for an importer. That could even be as simple as a ‘sticker’ applied to a product, where the sticker was supplied by the importer.
This is the essence of how the story came to our attention. In dealings with a long time friend in the transportation industry they reached out to us when they encountered an issue with acquisition of trailers. They indicated this issue was rather large for the transportation industry as “many carriers ship down equipment, decals etc. to be installed on the trailers at the factory”. It happens across many industries where these inputs to the manufacturing/assemble process include components provided by the importing customer of the manufacture/assembler. The issue caused by assists is typically one of incorrect valuation of an imported product. In their own words they said “It is a little scary when both the importer and the importer’s customs broker are unaware of what assists are and I have to send the customs broker the link to the D-memo…” As in every industry it goes without saying that not all providers are equal, thankfully he came to GHY International for help. This is a typical story we hear often and they are good opportunities for an audit…many stones to be turned over and lots of issues to find.
The story is ‘no surprise’ as assists almost always impact ‘manufacturers’ but further impact importers (and global traders)
Plus at least once a year the term ‘assist’ moves to the forefront for an information ‘blast’
When Customs find ‘assists’ the enforcement opportunity is ‘significant’ as they have the ability to apply against ‘all impacted transactions’ (we’ve seen it happen)
Your Next Steps
Review your manufactured products, assemblies or sub-assemblies, do you provide any parts, packaging, labels, tools, dies, etc. to allow the foreign manufacture to create/assemble the product you ordered from them? If yes those are assists and the value of those goods must be included in the imported goods value. Of course if you imported those assists then you could be entitled to a drawback, but that is another issue altogether and one we have shared with you already.
You will need the help of your professional trade services provider and potentially your legal counsel in order to prepare and protect you from liabilities created due to improper declaration of value, commonly referred to as valuation issues.
Again these interactions between imports and exports speak to the reason to implement an Integrated Trade Compliance Strategy.