Photo of Martín Yerovi

Martín Yerovi is an international trade analyst in Crowell & Moring’s Washington, D.C. office. He provides practice support to the International Trade Group on import regulatory matters pending before the Office of the U.S. Trade Representative (USTR) and U.S. Customs and Border Protection (CBP). He works closely with attorneys developing courses of action for clients impacted by investigations under Section 301 of the Trade Act of 1974 and Section 232 of the Trade Expansion Act of 1962. He also supports unfair trade investigations, including antidumping (AD) and countervailing duty (CVD) investigations, sunset reviews, and changed circumstance reviews before the Department of Commerce and the International Trade Commission (ITC).

Main Idea: Subheading 9817.60.0000 provides a significant duty-saving opportunity for importers, so long that the subheading’s very specific requirements are met.

In ruling N273612 (Mar. 31, 2016), U.S. Customs and Border Protection (CBP) discussed the tariff classification of various equipment and goods used for the Copa América Centenario, referred to in English as

Main Idea: Subheading 8714.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), covers parts and accessories exclusively for “carriages for disabled persons,” but does not cover items that have multiple uses even if one of the uses is acting as a carriage for disabled persons.

In ruling N328762, (Nov. 8, 2022) U.S. Customs

Main Idea: Classification of apparel items requires a specifically robust understanding and reading of the applicable Section and Chapter notes, as noted by the unisex and water repellant provisions of Chapter 62.

In ruling N328725 (Oct. 28, 2022), U.S. Customs and Border Protection (CBP) discusses the tariff classification of a unisex children’s jacket from

Main Idea: Comprehensive understanding of tariff classification and country of origin determinations is necessary for importers to determine the full scope of duties that may be applicable to their merchandise.

In N328620 (Oct. 27, 2022), U.S. Customs and Border Protection (CBP) discussed the tariff classification and country of origin marking for a steel racking

Main Idea: Individuals or companies that do not possess customs broker licenses and recommend HTSUS subheadings for customers to use when making entry violate the customs laws when (i) customers request subheadings to use and (ii) unlicensed individuals or companies provides specific subheadings for specific goods that will be subject to entry when customers

Main Idea: GSP eligibility requires in that an article be wholly the growth, product, or manufacture of a beneficiary developing country listed under GN 4(a) of the HTSUS, and applies provided that the article’s HTSUS classification and country of origin are not listed under GN 4(d).

In ruling N328056 (Oct. 4, 2022), U.S. Customs

Main Idea: Chapter 98 classifications can be a significant opportunity for duty-savings, but require robust tracing and recordkeeping processes from importers.

In ruling H323401, (Sept. 29, 2022) U.S. Customs and Border Protection (CBP) considers the applicability of secondary subheading 9801.00.10, HTSUS for certain retail bags of frozen fruit (e.g., strawberries or fruit medleys).   

Main Idea: Proper classification under the HTSUS relies heavily on a complete and robust understanding of the applicable Section and Chapter Notes.

In ruling N328096 (Sept. 26, 2022), U.S. Customs and Border Protection (CBP) discusses the tariff classification of the below styles of men’s swim trunks from China.  

Style NumberDescription of Item

Main Idea: The constituent component that is key to how the good is used may impart essential character to a composite good and determine classification under the HTSUS.

In ruling NY N327871 (Sept. 12, 2022), U.S. Customs and Border Protection (CBP) determines the tariff classification of birdfeeders from China.  CBP reviews three specific products:

In ruling N327712 (Sept. 2, 2022), Customs and Border Protection (CBP) discusses the country of origin of an electronic vaping device.  The device under review, identified as the Vuse Alto Power Unit, is an electronic vaping device comprised of the following components:

  • Metal enclosure containing a printed circuit board assembly (PCBA);
  • Rechargeable battery;
  • Battery plugs;