---
name: "customs_trade_compliance"
description: "Run import and export compliance workflows: HS tariff classification with GRI reasoning, sanctions and denied-party screening, export documentation and Incoterms. Triggers when a shipment needs a compliance checklist, a product needs an HS code, parties need sanctions screening, or Incoterms need to be assigned."
---

# Customs Trade Compliance

## Purpose

Turn a planned shipment into a defensible compliance record. The skill walks an agent through the four steps every cross-border shipment needs: classify the goods (HS code), screen the parties and end-use, prepare the documents, and assign delivery terms (Incoterms 2020). It produces a per-shipment checklist you can actually tick off, plus the reasoning behind the classification and screening decisions. It is an advisory tool, not legal advice. Binding classification rulings and licensing calls go to a licensed customs broker or trade attorney.

## Workflow

1. **Collect the facts.** Get the product description, bill of materials, materials and function, country of origin (per substantial-transformation rules, not just the shipping country), destination, value, all parties (buyer, seller, broker, forwarder, bank, end-user, intermediate consignee), and the proposed Incoterm.

2. **Classify (HS code).** Work the 6-digit HS structure: chapter (2 digits), heading (4), subheading (6), then national extensions (US HTS/Schedule B add to 10). Apply the General Rules of Interpretation in order and write down the GRI path for anything non-obvious. Check the destination authority's current tariff schedule (US: hts.usitc.gov). Record the duty rate, admissibility requirements, and any license flags the code carries. When torn between codes, read the section and chapter notes; they outrank gut feeling. When truly stuck, request a binding ruling from the destination customs authority instead of guessing. Never pick a code to lower duty. Details: `references/hs-classification-guide.md`.

3. **Screen (sanctions and export controls).** Screen every party against the OFAC SDN list and the BIS lists (Entity List, Denied Persons List, Unverified List, Military End-User List); the Consolidated Screening List at trade.gov/consolidated-screening-list covers Commerce, State, and Treasury lists in one search. Apply the OFAC 50-percent rule: entities 50% or more owned by sanctioned persons count as blocked. Check the end-use against BIS red flags: vague end-use, item mismatched to the customer's business, third-country payment, circuitous routing, refused installation or warranty. If the item is on a control list or the destination or end-user triggers restrictions, get the right license (BIS for EAR goods, State/DDTC for ITAR defense articles) before the shipment moves. File the screening results with the shipment records.

4. **Document.** Verify the commercial invoice carries every required element: all parties with names and addresses, invoice date, PO number, port of entry, country of origin, payment terms, Incoterm, detailed item descriptions, and HTS/Schedule B numbers. Prepare the packing list and the transport document (bill of lading or air waybill). For US exports: file EEI in AES/AESDirect when triggered (most exports over $2,500 per Schedule B number; licensed, sanctioned, ITAR, or rough-diamond goods file regardless of value), receive the ITN, and annotate the "AES [ITN]" proof of filing on the invoice, packing list, and waybill. Add the Destination Control Statement to the invoice and transport document for controlled items. Prepare certificates of origin when claiming FTA duty savings. Details: `references/doc-checklists.md`.

5. **Assign Incoterms.** Confirm one of the 11 Incoterms 2020 rules in writing and record who bears export clearance, main carriage, insurance, import clearance, and duties, plus where risk transfers. EXW leaves export clearance to the buyer; FOB splits at the vessel with the seller clearing export; CIF has the seller pay freight and minimum insurance to the destination port while risk still passes at loading; DDP puts almost everything on the seller including import clearance and duties. Incoterms set cost, risk, and clearance obligations only, not ownership or payment terms. Full table: `references/incoterms-table.md`.

6. **Generate the checklist and keep records.** Run `bin/compliance-checklist.py` with the shipment facts (see below) and work the checklist to completion. Retain every record for 5 years from export or entry (7 years for ITAR/State Department records). If an audit arrives, the classification rationale and screening results are your defense.

### Checklist generator

Feed it a JSON file describing the shipment:

```json
{
  "description": "500 lithium-ion power banks, 20,000 mAh",
  "origin_country": "CN",
  "destination_country": "US",
  "value_usd": 12000,
  "incoterm": "FOB Shenzhen",
  "transport_mode": "sea",
  "hs_code": "8507.60.00",
  "us_origin_export": false,
  "parties": [
    {"name": "Acme Trading Ltd", "role": "seller"},
    {"name": "Bright Retail Inc", "role": "buyer"},
    {"name": "FastForwarder Co", "role": "freight forwarder"}
  ]
}
```

```bash
python3 ~/workspace/skills/customs-trade-compliance/bin/compliance-checklist.py shipment.json > checklist.md
```

The script prints a Markdown checklist with unchecked items for classification verification, per-party screening, documents, Incoterm obligations, and recordkeeping. Unchecked means unverified: do the work, then check the box.

## Output Contract

Every run produces:
- A per-shipment checklist (from the generator or built by hand) covering classification, screening, documents, Incoterms, and recordkeeping, with each item checkable.
- An HS classification statement: code, the GRI path used, the tariff schedule consulted, and any license flags or duty notes.
- A screening record: which lists were searched, the parties screened, any matches or 50-percent-rule considerations, and the red-flag review outcome.
- A document list: which documents are prepared, EEI filing status (ITN when filed), and certificate-of-origin status for FTA claims.
- An Incoterm confirmation: the term chosen, who handles export and import clearance, where risk transfers, and insurance responsibility.

## Operating Rules

1. Every factual claim must be verified against a primary source or web search. Tariff rates change; never quote a duty rate from memory. Cut what you cannot verify.
2. This skill advises and organizes. It does not issue binding classifications, license determinations, or legal opinions. Say so plainly when the stakes are real.
3. Screen before you ship, every time. Screening is per shipment and per party, not per year.
4. Keep classifications consistent across the invoice, packing list, and customs forms. One product, one code, everywhere.
5. Retain records for the full retention period. If it is not documented, it did not happen when customs asks.