New ARSA Guidance Clarifies Duty-Free Aviation Parts Importation Rules
ARSA has released new guidance aimed at helping the aviation maintenance industry import parts for repair in order to more efficiently do business internationally.
Under U.S. law and international agreements, many aircraft parts may be imported into the United States duty-free. However, inconsistent interpretation of Customs rules has forced repair stations to divert resources to navigating a complex regulatory web and in some cases paying import duties they do not owe.
ARSA’s new Advisory 2017-01 provides an overview of the World Trade Organization’s Agreement on Trade and Civil Aircraft and rules adopted in the United States to implement the treaty obligations. The document also delves into relevant Customs regulations and legal opinions to answer a basic question: Must parts be airworthy to qualify for duty-free treatment? ARSA’s conclusion, with which Customs concurs, is that airworthiness is not a relevant factor in the duty-free determination. The association’s guidance examines the various conditions that must be met to avoid tariffs and identifies best practices to properly document imports. The association has also released a new on-demand training session (see below) about the parts importation issue.
The guidance and training were developed in direct response to questions raised by ARSA members at the association’s 2017 Symposium in Washington, D.C. “Issues like the tariff treatment of aircraft parts and inconsistent enforcement have a direct impact on our members’ bottom lines,” ARSA Executive Vice President Christian A. Klein said. “We hope these new resources, particularly [Advisory 2017-01], will help repair stations save time and money while more efficiently serving their international customers.”
The guidance is available for free to ARSA members and may be ordered by visiting arsa.org/publications or completing the form below.
To see all of the association’s resources for establishing duty-free rates, visit arsa.org/regulatory/customs.
On Demand Training: Duty-Free Parts Importation
On Oct. 11, Executive Vice President Christian A. Klein hosted an hour-long session on parts importation requirements. Klein reviewed the issues surrounding duty-free import of civil aviation parts and articles and introduced the association’s resources for managing the process. Attendees will be given access to the ARSA Advisory 2017-01, “Importing Parts for Repair Duty Free Under 19 CFR § 10.183.”
More information on the issue can be found at: arsa.org/regulatory/customs.
Importing Aircraft Parts for Maintenance – Establishing Duty Free Rates
The session reviews the World Trade Organization’s exemption of civil aviation products and parts from import duties and describes the U.S. implementation of rules and guidance to support duty-free importation. It then walks through the association’s resources for ensuring that eligible imports are made free of Customs tariffs.
Registration for an ARSA-provided training session includes:
- Unlimited access for 90 days to the recording made available after the live session is complete.
- A copy of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of the class, as well as any test material.
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, PLC, the firm that manages ARSA. To go directly to OFMK’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.