1. Identify the importer and decision owners
Determine which party will be the importer of record and who owns product-regulatory, customs, trade, safety-data, logistics and commercial decisions. A licensed customs broker can file entries, but the importer retains responsibilities for the accuracy and support of entry information.
Document authority, information flow, broker instructions, recordkeeping and escalation before freight is booked.
2. Build a complete product fact file
Organize the chemical identity, composition where required, physical form, intended use, technical specifications, supplier and manufacturer, country of manufacture, packaging, quantity, value, customer, end use and available regulatory records.
Protect confidential business information through appropriate processes, but make sure the responsible specialists can obtain the facts needed for a defensible determination.
3. Confirm tariff classification, value and origin
Licensed customs brokers and trade counsel can help determine the Harmonized Tariff Schedule classification, customs value, country of origin, normal duties and additional tariffs or trade measures that may apply.
Do not select classification or origin solely from a competitor’s invoice or a broad product description. The product facts and applicable legal rules control the analysis.
- HTS classification and supporting rationale
- Customs value, assists and related-party considerations
- Country-of-origin analysis and marking
- Normal duty and additional tariff exposure
- Broker instructions, bond and entry documentation
4. Confirm TSCA status and certification
EPA states that imports of chemical substances or mixtures must comply with TSCA to enter the United States and generally require the applicable positive or negative certification. Import can also constitute manufacture under TSCA for purposes including new-chemical and significant-new-use requirements.
Confirm inventory status, applicable rules or orders, exemptions, intended uses, volume limits, reporting and certification with qualified product-stewardship or regulatory specialists. Do not assume a product sold elsewhere is automatically ready for U.S. import.
5. Align the U.S. hazard communication package
Manufacturers and importers should confirm applicable OSHA Hazard Communication requirements for hazard classification, labels and safety data sheets. Make sure the U.S. customer receives the correct current documentation and that product identity and shipment documents remain consistent.
Coordinate version control, emergency contacts, language, transport classification and customer technical files across manufacturer, importer, warehouse and distributor.
6. Add sanctions, export-control and counterparty screening
Screen parties, ownership, banks, destinations, end users and end uses against applicable restrictions. Product and technology controls can matter even when the commercial destination is the United States, especially when information, samples, payments or reexports involve other countries.
An unresolved match, ownership question, restricted end use or other red flag should pause the transaction for qualified review.
7. Connect compliance facts to landed cost and customer promises
Classification, origin, duties, certification, labeling, testing, inventory and broker requirements affect price, lead time and working capital. Commercial teams should not promise price or delivery until these facts are reflected in the operating plan.
Create a pre-shipment gate with named approvals and preserve the supporting records. Repeat the review when product, composition, use, supplier, origin, customer or regulation changes.