Shipment Flow — Factory Floor to U.S. Warehouse
Origin Port
Ocean Transit
CBP Entry Filing
HTS Classification
Duty Payment
FDA Review
Last-Mile Delivery
Every Thread
Accounted For.
Garment-specialist customs brokerage for apparel brands importing from Dhaka and Ho Chi Minh City. HTS classification, FDA holds, duty recovery — handled before your container hits the dock.
10,000+
Garment shipments cleared
0
Shipments lost or abandoned
48 hr
Avg. FDA hold response
$2.4M
Duty recovered for clients (2025)
Every garment has an HTS code.
Finding the right one saves money.
HTS Decision Tree — Apparel Garments
Cotton ≥ 85% by weight
T-shirts, singlets, jerseys
6109.10
16.5%
MMF (polyester/nylon) ≥ 85%
Synthetic performance jerseys
6109.90
32.0%
Cotton 36–84% + synthetic blend
Fiber chief weight governs
6110.20 / 6110.30
20.0%
Cotton ≥ 85% by weight
Dress shirts, woven blouses
6205.20
19.7%
Wool ≥ 85% by weight
Blazers, suit jackets
6203.31
20.0% + specific
Synthetic ≥ 85% (woven)
Track suits, ski suits
6211.43
16.0%
Poly-cotton blend (chief weight)
49% vs 51% cotton = different chapter
6205.30 / 6205.20
Varies
Fiber Content Threshold Reference — Chief Weight Rule
* Chief weight = the single fiber comprising the greatest weight percentage. When two fibers are equal, the one with the higher duty rate governs.
Compliance isn't a checkbox.
It's a strategic position.
CBP Voluntary Programs — Eligibility & Benefits
C-TPAT
Tier 1–3
U.S. importers with ≥ 2 years import history, documented supply chain security procedures
Reduced exam frequency, front-of-line exam priority, ISA eligibility
6–12 months to certification
RecommendedISA
Voluntary
Active C-TPAT member, internal trade compliance program, CBP audit readiness
Self-directed compliance, reduced CBP oversight, ACE Portal access
12–18 months post C-TPAT
AdvancedReconciliation
Post-Entry
Any importer; flagged entries must be reconciled within 21 months of original entry
Correct duty basis after final price/quantity known; FTA claims post-import
Per entry cycle
StandardACE
Mandatory
All importers; required for all CBP filings since Feb 2016
Single window filing for CBP + PGA (FDA, CPSC, FWS) submissions
Immediate
RequiredIPR
Protective
Brand owners with registered trademarks/copyrights; CBP recordal via e-Recordation
CBP seizure authority on counterfeit garments; exclusion orders at port of entry
30–60 days recordal
Brand ProtectionISF 10+2 Filing Requirements — Ocean Imports
* ISF penalty: $5,000 per violation for late/inaccurate filing. Clearance files ISF as your licensed broker — never a day late.
A hold notice at 5 PM Friday
is not a crisis if you know the playbook.
FDA Hold Resolution Protocol — Apparel & Textile Imports
FDA issues DWPE (Detention Without Physical Examination) or exam notice via ACE. Clearance receives automated alert within 2 hours of CBP system update.
Determine hold basis: Textile Fiber Products Identification Act (TFPIA) labeling, country of origin discrepancy, prior import violation, or random exam.
If physical exam required, coordinate with FDA-approved exam site. Textile sampling follows 21 CFR Part 1 procedures. Results typically 3–5 business days.
Submit Notice of Intent to Present Testimony or Offer for Reconditioning. For labeling violations: corrected labels + affidavit. For origin: additional documentation or lab testing.
FDA issues Release, Conditional Release, or Refusal. Conditional Release requires reconditioning under FDA supervision. Refusal triggers re-export or destruction within 90 days.
Common FDA Hold Causes — Apparel & Textiles
Duties paid are not always
duties owed. Here's the difference.
99%
Max drawback recovery on eligible entries
5 yrs
Filing window for manufacturing drawback
$0
Clearance fee on drawback below recovery
18 mo
Avg. Section 301 refund processing time
Duty Drawback Programs — Apparel Importers
Recover 99% of duties paid on imported fabric/materials used to manufacture garments subsequently exported.
Recovery
Up to 99%
Example: Import woven fabric from Vietnam ($50K duty paid) → Cut & sew blazers → Export to Canada → Recover $49,500
Recover 99% of duties on imported merchandise exported in same condition without use in the U.S.
Recovery
Up to 99%
Example: Import 500 units knitwear, sell 300 domestically, re-export 200 to EU → Recover duties on re-exported 200 units
Recover 99% of duties on merchandise that does not conform to sample/specification or was shipped without consent.
Recovery
Up to 99%
Example: 200 units knitwear received with wrong fiber content (spec: 85% cotton, actual: 72%) → Reject → Recover duties
File for retroactive exclusion on China-origin goods subject to Section 301 tariffs (Lists 1–4A) where exclusion was granted.
Recovery
100% of 301 duties
Example: $200K Section 301 duties paid on polyester athletic wear → Matching exclusion identified → File for refund
First Sale Valuation — Reduce Dutiable Value at Entry
When a garment passes through a middleman (agent/trading company) before reaching the U.S. importer, duties are typically assessed on the final invoice price. First Sale allows declaration on the factory-to-middleman price — the lowest legitimate transaction value in the chain.
Savings example: Factory price $8.00/unit → Middleman markup → Final invoice $11.00/unit → 1,000 units × 20% duty rate → First Sale saves $600 per shipment.
FTZs are not for everyone.
Here's who they're actually for.
FTZ Viability by Import Volume — Apparel Importers
FTZ Merchandise Status Options
Duty assessed at HTS/rate at time of admission. Protects against future duty increases on goods already in zone.
Best for: Importers expecting tariff increases; goods with long dwell time
Duty assessed at HTS/rate of the manufactured product when transferred to U.S. commerce. Allows zone-to-zone manipulation.
Best for: Manufacturers using FTZ for production; finished goods have lower duty than inputs
Duty-paid merchandise admitted to zone retains domestic status; can be mixed with foreign merchandise.
Best for: Bonded warehouse consolidation; returned goods management
Merchandise transferred between FTZ sites without formal CBP entry. Useful for multi-site production operations.
Best for: Multi-location garment manufacturers with separate cut/sew and finishing operations
FTZ Setup Requirements & Timeline
Your container shouldn't
be a question mark.
Send us your product details and we'll review the HTS classification, check for duty recovery opportunities, and flag any FDA compliance gaps — at no charge for the initial review.
No commitment. Response within 48 business hours.