One of them is criteria change in customs valuation rule traders need to know.
Here is summarize of important one, which is "assist element" in manufacturing.
Customs Tariff Law Basic Notification 4-2-3, Guidance of inspection cost for imported goods
In customs valuation rule, Customs Tariff Law Basic Notification 4-2-3 describe as "the cost for inspection of goods which buyer go to seller's site and inspect the goods in seller's manufacturing process is NOT included in transaction value".
However, if the buyer is involved in "work of manufacturing" other than inspection work, such cost relating to manufacturing must be added into transaction value.
As major manufacturers' supply chain is getting global, it happens quite often that engineers in headquarter visit overseas manufacturing site and provide technical support.
It has been challenging issues how to treat such cost of technical support, whether to include in customs transaction value or not.
Update in basic notification this time provide much clearer criteria in such a case.
Former notification provided the definition of "manufacturing work" to be added to customs transaction value as below four criteria.
- Work for processing or manufacturing
- Production control
- Operaiton progress control
- Transportation for processing or manufacturing
Apparently, 1 and 4 are understandable as manufacturing work, but 2 and 3 have vague meaning, including management work, and difficult to judge in real operation. Update of notification this time deleted both 2 and 3, then only 1 and 4 remain. This update would give much clearer definition!
In addition, as expenses to be added to customs transaction value for person who engages in manufacturing work, the former notification provided following five elements.
- Voyage expense (including preparation expense)
- Expense during the stay
- Labour cost (including wage and bonus in home country)
- Expense for taking care of absent home during the trip
- Other expenses related to above.
It looks former notification covered all kinds of related expenses broadly! Update this time focus more specifically and prescribe only as below expenses.
- Voyage expense (including preparation expense)
- Expense during the stay
- Wage (expense equivalent to direct labor cost)
In the new notification, it is not required to include bonus or welfare program expense into customs transaction value. This criteria change could be positive news for global manufacturing players who have been worried about definition of customs valuation assist elements.
(Source: http://www.customs.go.jp/kaisei/tsutatsu/H21tsutatsu/H21tsutatsu0368/H21t0368_annex02.pdf - Japanese only)
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