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The first sale rule allows duty to be based on the sale of goods from the manufacturer to a middleman/vendor in qualifying multi-tiered transactions rather than the sale from the middleman/vendor to the importer. It is a highly effective method for legitimately lowering import tariffs and one that is increasingly utilized to mitigate the impact of Section 201, 232, and 301 tariffs.

Sandler, Travis & Rosenberg litigated the case that established the first sale rule under U.S. law in 1988 and in 2008 led a coalition that secured legislation affirming first sale when U.S. Customs and Border Protection threatened to discontinue it. ST&R has also developed a secure online portal for first sale clients that streamlines the implementation process; provides real-time access to project status, tasks, and timelines; and secures client data to support compliance and reliable recordkeeping.

Why Use ST&R’s First Sale Services

Cost savings: We’ve successfully implemented hundreds of first sale programs that have lowered import tariffs for our clients. 

Certainty: First sale offers a proven way to lower tariffs in an uncertain global trade environment.

Experience: Our U.S.- and Asia-based first sale professionals include former regulatory auditors and attorneys with extensive experience in valuation matters.

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