CUSTOMS SHOULD REWRITE DECISION, MAKE IT WORKABLE

CUSTOMS SHOULD REWRITE DECISION, MAKE IT WORKABLE

The April 25 article regarding the declaration of freight amounts on Customs entries (''Importers reminded of 'reasonable care' on freight costs,'' Page 3) points up the futility of over-regulation, as well as the public's apprehension about Customs' definition of ''reasonable care.''

The recent Treasury decision would seem to compel brokers and importers to submit a written statement on each entry when the freight amount is unknown.So much for paperless documentation. Even more ridiculous is the requirement that a subsequent statement be given if the information cannot later be obtained.

Customs headquarters is pleading with the trade community not to give them reams of paper at each port of entry. But importers may have no alternative unless Customs simplifies compliance.

In the meantime, foreign shippers are being innovative. Recently, a shipper created an f.o.b. invoice to his customer. But the terms of the shipment were really DDP.

To get around it, the shipper had a freight forwarder arrange a ''route code'' movement, and instruct the U.S. Customs broker to bill the forwarder for duty and charges. The forwarder then billed the shipper for everything.

Years ago, c.i.f. shipments were simple. Sellers had to show, on the Customs or commercial invoice, the charges included in the c.i.f. price. The importers simply deducted those non-dutiable charges at time of entry.

It was simplicity itself. Customs accepted the shipper's statements. It could work again.

It's to be hoped that this confusion will finally convince importers that f.o.b. purchases are preferable, and cheaper in the long run.

But, in the meantime, Customs owes it to itself and to the public to rewrite Treasury Decision 00-20 to make it workable.

M. SIGMUND SHAPIRO

Chairman and CEO

Samuel Shapiro & Co.

Baltimore

POLITICAL PERVERSION OF ANTI-DUMPING LAW IS NOT AN ANOMALY

I cannot help but respond to the April 19 letter from the Economic Strategy Institute of Washington (''Editorial on dumping was contradictory, distorted, inaccurate,'' Page 7) about your editorial of April 11 titled ''Dump the dumping law'' (Page 5).

As a seafood importer subjected to what has to be one of the most politically motivated dumping cases ever brought, which involved crawfish tailmeat from China, I can attest firsthand to the accuracy of the editorial, which cited the use (misuse) of the anti-dumping laws to grant protectionist favors to specific industries.

Too many federal and state politicians wave a free-trade flag with one hand but collect special-interest votes and support with the other. One need look no further than the public record in the crawfish case - a case full of far more letters from federal and state politicians than true domestic-industry voices.

I fully advocate the existence of U.S. anti-dumping provisions to protect domestic industry from clear unfair trade practices.

However, I have no doubt that political perversion of this law, as in the crawfish case, is not an anomaly.

Your readers and the rest of the business community should not be misled by the April 19 letter.

MATTHEW FASS

Williamsburg, Va.