MJ USA Customs | Services

1. Section 301 & 232 Tariff Mitigation Strategy

Evolving USTR mandates require aggressive portfolio protection. We assist importers in structuring global supply chains to reduce exposure to punitive tariff lines using methodologies consistent with established substantial-transformation precedent.

Exclusion Verification: Auditing SKU databases against USTR forced-labor exclusions and specific structural exceptions.

Lawful Product & Process Restructuring: Evaluating component sourcing and manufacturing sequencing to determine legitimate eligibility for lower-rated HTS provisions.

Sourcing Adjustments: Verifying Country of Origin rules to prevent illegal transshipment exposure during supply line transitions.

2. CBP Audit Defense & Enforcement Advisory

Responding incorrectly to a Customs Form 28 (CBP Request for Information) or Form 29 (Notice of Action) can lead to full regulatory enforcement actions. We protect your company through rigorous defensive mitigation protocols.

Audit Representation: Serving as the primary expert liaison for companies undergoing focused assessments or quick-targeted audits.

Prior Disclosures: Preparing and filing voluntary compliance disclosures to fix historic entry errors while mitigating statutory penalties.

Protest Filings: Researching and submitting legal arguments to challenge adverse customs liquidations within the 180-day regulatory window.

3. UFLPA & Forced Labor Supply Chain Compliance

The Uyghur Forced Labor Prevention Act has fundamentally shifted the evidentiary burden onto importers under a rebuttable presumption standard. We build the documentation infrastructure your company needs to demonstrate admissibility before goods are detained at the port.

Multi-Tier Supply Chain Mapping: Tracing raw inputs (aluminum, PVC, silica, cotton) through sub-tier suppliers back to origin.

Detention & Exclusion Response: Assembling clear and convincing evidentiary packages to challenge CBP detentions within strict 30-day windows.

Vendor Attestation Frameworks: Implementing supplier auditing and document-retention protocols to maintain ongoing admissibility.

4. HTS Classification, Valuation & Binding Rulings

Importers bear strict legal liability under the Mod Act for providing correct classification and valuation metrics to federal agencies. We establish defensible baseline structures for your entry portfolios.

HTS Database Engineering: Building fully researched, audit-defensible classification databases for enterprise product catalogs.

CBP Binding Rulings: Drafting and submitting formal e-Ruling requests (HQ/NY) to resolve regulatory ambiguity for complex products.

Valuation & First Sale Optimization: Reviewing transfer pricing, assists, and transaction value methodologies to determine lowest lawful customs values.

5. Antidumping & Countervailing Duty (AD/CVD) Advisory

AD/CVD orders and EAPA evasion investigations carry some of the steepest duty rates and administrative risks in trade law. We help importers determine scope exposure and defend against circumvention allegations.

Scope Ruling Analysis: Reviewing product specifications against active AD/CVD orders to secure formal in-scope or out-of-scope determinations.

EAPA Evasion Defense: Representing importers under Enforce and Protect Act investigations alleging transshipment or misdeclaration.

Circumvention Audits: Evaluating foreign assembly and third-country processing locations to flag exposure before orders expand.

6. USMCA Compliance & Regional Origin Verification

The activation of the USMCA sunset review mechanism has created severe compliance pressure across North American supply chains. We ensure products satisfy strict regional rules of origin to maintain duty-free entry status.

Rules of Origin Mapping: Executing regional value content (RVC) and tariff-shift calculations under updated industrial standards.

Certification Management: Drafting and validating robust Certificates of Origin to survive CBP border verification audits.

De-risking Foreign Content: Auditing North American manufacturing processes to ensure secondary foreign components do not trigger transshipment penalties.

7. Free Trade Agreement (FTA) Utilization & Financial Analysis

Millions of dollars in preferential tariff savings go unclaimed due to administrative complexity. We perform rigorous evaluations of your supply network to maximize lawful trade agreement utilization.

Utilization Auditing: Reviewing historic import records to identify missed duty-free eligibility pathways across bilateral and plurilateral FTAs.

Cost-Benefit Financial Analysis: Modeling net operational savings against administrative compliance costs to validate FTA adoption.

Supplier Origin Tracking: Implementing compliance screening to verify foreign vendor documentation back to raw material inputs.

8. Duty Drawback Recovery

Duty drawback remains one of the most underutilized duty recovery mechanisms available. We identify, structure, and process legitimate refund claims on duties, taxes, and fees previously paid on imported merchandise.

Eligibility Screening: Identifying unclaimed manufacturing, unused merchandise, and rejected merchandise drawback opportunities.

Claim Preparation & Filing: Assembling supporting transaction documentation and filing accurate, audit-ready drawback claims with CBP.

Accelerated Payment Setup: Establishing privilege applications and recordkeeping systems for recurring duty recovery.

9. Customs Fraud & False Claims Act Defense

Duty evasion schemes carry severe civil and criminal exposure under 19 U.S.C. § 1592 and the False Claims Act. We advise importers seeking to remediate internal exposure and entities navigating federal inquiries.

Internal Risk Assessment: Auditing entry practices, valuation, and origin declarations for red flags associated with federal fraud investigations.

Remediation & Disclosure: Structuring corrective action plans and voluntary disclosures to limit statutory penalty exposure.

10. Partner Government Agency (PGA) & CPSC eFiling Compliance

Non-customs entry holds from Partner Government Agencies can paralyze logistics networks. We ensure seamless pre-clearance filings across specialized federal health, safety, and environmental regimes.

CPSC eFiling Integration: Pre-filing Certificate of Compliance (CPC/GCC) data via the ACE PGA Message Set prior to port arrival.

11. Foreign Trade Zone (FTZ) & Bonded Warehouse Operations

Defer, reduce, or eliminate import duties by leveraging special customs secure territories. We assist companies in evaluating, applying for, and operating active Foreign Trade Zone subzones.

Inverted Tariff Savings: Structuring FTZ manufacturing operations to pay lower finished-good duty rates instead of higher component rates.

12. Export Controls & Sanctions Compliance (EAR / ITAR / OFAC)

Export enforcement failures carry catastrophic criminal penalties, administrative fines, and denial of export privileges. We build robust Export Management and Compliance Programs (EMCP) tailored to dual-use technologies, defense articles, and international commercial networks.

License Application Management: Drafting, filing, and managing export license applications via BIS SNAP-R and DDTC DTrade/DECCS portals.

Foreign Direct Product Rules (FDPR): Navigating complex export restrictions on advanced microelectronics, AI computing clusters, and semiconductor manufacturing equipment.

13. C-TPAT & Supply Chain Security Certification

Membership in the Customs Trade Partnership Against Terrorism (C-TPAT) reduces examination rates and grants priority processing. We guide companies through certification, validation, and security maintenance.

Portal Maintenance & Validation Defense: Managing annual C-TPAT portal updates and preparing teams for CBP field validation audits.

14. Embedded Corporate Contracting & Special Project Placement

Bridge critical personnel gaps with senior trade leadership. Designed for multinational corporations and Tier 1 advisory firms (including Big Four frameworks), Mark Jones steps directly into your enterprise as an embedded contract officer, providing daily hands-on leadership.

Big Four / Consultancy Subcontracting: Partnering with tier-one global consulting firms to execute specialized, deep-dive compliance audits.

15. Retainer & Fractional Trade Counsel

Not every organization requires a full-time internal trade compliance department. We offer ongoing, fractional advisory coverage so your leadership team always has senior trade expertise on call.

Monthly Advisory Retainer: Standing access to senior trade guidance for daily classification, origin, and entry questions.

Quarterly Portfolio Audits: Scheduled compliance reviews to catch drift in classification, origin, or valuation practices before they trigger CBP holds.

16. Trade Compliance Training & Executive Briefings

Regulatory literacy inside your organization is your first line of defense. We deliver practical, executive-level training built around active enforcement trends rather than generic compliance theory.

Corporate Team Workshops: Customized sessions for procurement, logistics, and legal teams on classification, origin, and audit-readiness.

17. Global Trade Management (GTM) & ERP System Audits

Automated compliance systems are only as good as their underlying master data. We review and optimize automated trade compliance modules to eliminate systematic errors.

GTM Master Data Cleanup: Auditing automated HTS, ECCN, and Country of Origin tables inside SAP GTS, Integration Point, or ONESOURCE.