Tariff Classification & HTS Code Disputes

Tariff lawyer in Calabasas and California. HTS classification attorney for customs disputes, CBP binding rulings, and tariff engineering.

International Trade & Customs Law Services

Comprehensive customs and tariff defense for California importers at the Port of Los Angeles, Port of Long Beach, and all U.S. ports of entry. Services include CBP audit defense, tariff classification, customs valuation, Section 301/232/IEEPA tariff strategy, UFLPA forced labor compliance, duty drawback recovery, and Court of International Trade litigation.

Current Tariff Landscape

With effective tariff rates at historic highs, California businesses need experienced trade counsel. We handle Section 301 China tariffs, Section 232 steel/aluminum tariffs, IEEPA tariff refund claims, and reciprocal tariff compliance.

Free consultation for importers: (818) 514-7680.

Filed Court of International Trade Actions

Trembach Law Firm is not only admitted to the U.S. Court of International Trade — it files its own IEEPA refund complaints there under 28 U.S.C. § 1581(i), with new complaints filed as importers sign. CBP deployed CAPE Phase 3 — which covers finally liquidated entries for plaintiffs holding a court reliquidation order — on October 6, 2026. As of October 28, 2026 the firm is counsel in 35 actions at the Court of International Trade, docket numbers 1:26-cv-04095, 1:26-cv-04154, 1:26-cv-04156, 1:26-cv-04164, 1:26-cv-04185, 1:26-cv-04248, 1:26-cv-04271, 1:26-cv-04277, 1:26-cv-04300, 1:26-cv-04327, 1:26-cv-04328, 1:26-cv-04335, 1:26-cv-04342, 26-04390, 26-04392, 26-04393, 26-04394, 26-04395, 26-04396, 26-04418, 26-04421, 26-04488, 26-04556, 26-04559, 26-04563, 26-04568, 26-04569, 26-04616, 26-04617, 26-04618, 26-04643, 26-04668, 26-04745, 26-04766, 26-04797 (list and verification: Court of International Trade filings). Anatolii Trembach is admitted to practice before the Court of International Trade and is licensed in California, State Bar #349304, verifiable at apps.calbar.ca.gov.

This matters for IEEPA refunds specifically. The Court of International Trade has ordered CBP to reliquidate and refund on plaintiffs’ entries, and CBP’s CAPE Phase 3 for finally liquidated entries is likewise available only to importers who are plaintiffs at the Court. An importer who never filed has no confirmed, self-executing mechanism. Choosing counsel who has actually filed at that court, rather than counsel who only describes the process, is therefore a practical question and not a marketing one.

Jurisdiction over these actions rests on 28 U.S.C. § 1581, and the window to sue runs under 28 U.S.C. § 2636(i). No particular outcome is promised or guaranteed.

Fees, Costs and Case Results

Representation in these matters is offered on a contingency basis covering attorney fees only: there is no attorney fee unless we recover, and clients remain responsible for case costs, such as court filing and service fees. The specific terms that apply to a matter are set out in the written fee agreement for that matter.

Where this site refers to a verdict, settlement or court order, that result was dependent on the facts of that case, and results will differ if based on different facts. Past results do not predict or guarantee the outcome of any other matter, and no particular outcome is promised or guaranteed.

Frequently Asked Questions

What is tariff classification and why is it important for California importers?
Tariff classification is the process of assigning the correct Harmonized Tariff Schedule (HTS) code to imported merchandise. This 10-digit code determines the applicable duty rate, eligibility for free trade agreement preferences, quota restrictions, and compliance with import regulations. For California importers processing goods through Los Angeles, Long Beach, and Oakland ports, proper classification directly impacts landed costs and competitiveness. Classification errors can result in significant duty underpayments, penalties under 19 USC 1592, and CBP audit exposure.
What are the General Rules of Interpretation (GRI) and how do they work?
The General Rules of Interpretation (GRI) are the legal framework codified at 19 USC 1202 that governs tariff classification analysis. GRI 1 requires classification according to heading terms and section/chapter notes. GRI 2 addresses incomplete articles and mixtures. GRI 3 resolves classification when goods are prima facie classifiable under multiple headings, including the essential character rule under GRI 3(b). GRI 4-6 provide additional guidance. Our tariff classification attorneys apply these rules systematically to support classification positions.
What is a CBP binding ruling and how can it protect my classification?
A CBP binding ruling under 19 CFR 177 is an official determination from Customs and Border Protection establishing the correct classification for specific merchandise. Binding rulings protect importers by establishing definitive classification positions that CBP must honor, eliminating penalties for entries made in accordance with the ruling, and providing certainty for business planning. Our binding ruling attorneys prepare detailed ruling requests with technical specifications, legal analysis, and supporting documentation.
How do I respond to a CF-28 Request for Information about classification?
A CF-28 Request for Information requires strategic response within 30 days. First, analyze the specific classification questions CBP is asking. Gather supporting documentation including product specifications, manufacturing data, and technical literature. Research CBP rulings and court precedent supporting your classification. Prepare a comprehensive written response with legal analysis under the GRI framework. Our CF-28 response attorneys help California importers prepare persuasive responses that protect classification positions.
What is the essential character test for classifying composite goods?
The essential character test under GRI 3(b) determines classification of composite goods made of different materials or components. Classification follows the material or component that gives the article its essential character, considering factors like the nature and role of components, bulk, quantity, weight, value, and the role each component plays in the use of the goods. Court decisions emphasize functional significance over mechanical measures. Our classification attorneys analyze composite goods using established legal precedent.
What penalties apply to tariff classification errors?
Classification errors can result in penalties under 19 USC 1592 based on culpability level. Negligent classification violations carry penalties up to 2x the loss of revenue or 20% of dutiable value. Gross negligence penalties reach 4x loss of revenue or 40% of dutiable value. Fraud penalties can reach 4x domestic value plus criminal prosecution. Our classification penalty attorneys defend against CBP penalty assessments and file mitigation petitions demonstrating reasonable care.
How do I file a protest challenging CBP's classification determination?
Protests challenging classification decisions must be filed under 19 USC 1514 within 180 days of liquidation. The protest should identify the specific entries affected, state the legal basis for challenging CBP's classification, present supporting evidence and legal arguments, and request the appropriate relief. Our protest attorneys prepare comprehensive classification protests and pursue further review through CBP headquarters or Court of International Trade litigation when necessary.
When should I consider Court of International Trade litigation for classification disputes?
Court of International Trade litigation may be appropriate when CBP denies your protest and substantial duty amounts are at stake, legal precedent supports your classification position, CBP's determination conflicts with court decisions, the classification issue affects multiple products or ongoing imports, or establishing binding precedent benefits your business. Our CIT litigation attorneys are admitted to practice before the Court of International Trade and have experience in classification cases.
What is tariff engineering and is it legal?
Tariff engineering involves legally structuring products, components, or import transactions to achieve the most favorable classification and lowest duty rates. This can include product design modifications, importing goods in different states of assembly, strategic sourcing decisions, and proper application of classification rules. Tariff engineering is completely legal when based on actual product characteristics and proper classification analysis. Our tariff engineering attorneys help California importers identify legitimate duty minimization opportunities.
How do I demonstrate reasonable care in tariff classification?
Reasonable care under 19 USC 1484 requires importers to use reasonable efforts to ensure accurate classification. This includes maintaining detailed product specifications and technical documentation, conducting classification analysis using proper GRI methodology, researching CBP rulings and court precedent, seeking professional guidance for complex classification issues, documenting classification decisions and reasoning, and updating classifications when products change. Our compliance attorneys help establish reasonable care documentation programs.
What classification issues commonly affect California technology importers?
California technology companies face unique classification challenges including semiconductor and integrated circuit classification under Chapter 85, computer vs. telecommunication equipment distinctions, multifunctional device essential character analysis, parts and accessories classification for tech products, software and embedded systems classification, and Section 301 tariff implications. Our Silicon Valley classification attorneys specialize in high-technology HTS issues.
How does Section 301 affect tariff classification strategies?
Section 301 tariffs add 7.5% to 100% additional duties on Chinese-origin goods depending on HTS classification. Classification determines which Section 301 list applies (List 1, 2, 3, 4A) and corresponding duty rates. Proper classification can mean the difference between 7.5% and 25% additional tariffs. Some classifications qualify for exclusions. Our Section 301 attorneys analyze classification implications for Chinese imports and identify optimization opportunities.

Contact Trembach Law Firm

Trembach Law Firm, APC

27001 Agoura Road, Suite 350, Calabasas, CA 91301

Phone: (818) 514-7680

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