Comprehensive Iran Sanctions, Jul 1st, 2010

Jul 1st, 2010

Comprehensive Iran Sanctions

Dear ORIA Member:

We have just been informed of the following information by our Washington Legal Council . President Obama is scheduled to sign the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010 later today. As a result, the embargo on the importation of Iranian-made carpets will become effective on September 29, 2010, which is 90 days from today.

It is the date of importation – or, more technically, the date of entry for consumption — that controls whether an imported carpet is subject to the embargo. The date of export from Iran is irrelevant. To avoid being caught in the embargo, Iranian origin carpets must be presented for entry for consumption to U.S. Customs and Border Protection and/or withdrawn from warehouse by September 28.

Note that the embargo will apply to any Iranian carpets that are in a customs warehouse, that is, carpets that are being stored in a bonded warehouse and have not yet been entered for consumption into the U.S. territory. No Iranian carpets will be permitted to enter the United States or its customs territory, including from a customs warehouse, after September 28.

Under CBP rules, entered means that the appropriate documentation has been filed with the port to secure the release of the merchandise or to withdraw it from warehouse, along with any estimated duties that may be due. If entry documents are submitted before merchandise arrives within port limits, the time of entry is when the merchandise arrives within the port limits.

For merchandise being withdrawn from a warehouse for consumption, the time of entry is when a properly completed Customs Form 7501, and any other required documentation, is filed with CBP and estimated duties, if any, are deposited.

ORIA members would be well advised to plan to present Iranian carpets for entry to CBP before the last day, September 28.

If you have any further questions, we strongly recommend that you contact your Customs Broker.

Sincerely,

Lucille J. Laufer
Executive Director

The Oriental Rug Importers Association, Inc.
100 Park Plaza Drive
Secaucus, New Jersey 07094
Tele: (201) 866-5054
Fax: (201) 866-6169