VES-3-02-OT:RR:BSTC:CCR H334641 HKC
Constantine G. Papavizas, Esq.
Winston & Strawn LLP
1901 L Street, N.W.
Washington, DC 20036
RE: Coastwise Transportation; Outer Continental Shelf; Cable Laying; 46 U.S.C. §§ 55102, 55103, and 55109; 19 CFR §§ 4.80a and 4.80b
Dear Mr. Papavizas,
This letter is in response to your September 19, 2023 ruling request on behalf of your client [ ] regarding whether vessel activities relating to the installation of a subsea power cable on the U.S. Outer Continental Shelf (“OCS”) by non-coastwise-qualified vessels, as described below, would violate the coastwise laws. Our decision follows.
FACTS
The following facts are from your September 19, 2023 ruling request and subsequent correspondence. Your client has been awarded the contract to provide inter-array subsea cable installation services at two separate offshore wind sites located off the coast of [ ] on the OCS. Both the [ ] located at [ ] and the [ ] located at [ ] will be developed by [ ].
At the project sites, the wind turbine generators (“WTGs”) will be connected to each other by subsea power cables or to an offshore sub-station by such cables (referred to as “inter-array cable installation”) and the offshore sub-station will be connected by subsea power cables to an onshore connection for the delivery of power to the local electrical grid (referred to as the “export cable installation”). This request concerns only the inter-array cable installation, which occurs entirely on the OCS more than three nautical miles from shore.
Your client proposes to utilize two non-coastwise qualified Cable Installation Vessels (“CIVs”) for this cable installation. These vessels are the [ ], registered in [ ] and constructed in [ ] and the [ ], registered and constructed in [ ]. The cable will be loaded aboard the CIVs either at a foreign port or at a U.S. port. Prior to loading, a foreign-flagged vessel may transport the cable from a foreign port to a U.S. port. The cable installation vessel will be crewed by marine crew and project crew who will perform all the functions associated with installing the power cable including project developer representatives who board the CIV to perform project oversight and inspection functions.
Prior to cable installation on the seabed, three types of preparatory work will be undertaken on these OCS sites. First, an out-of-service (“OoS”) cable removal vessel will utilize a grapnel to pick up abandoned OoS cable from the seabed, cut the cable, and deliver cable sections to a coastwise-qualified vessel for delivery to a U.S. port for recycling. If the use of a grapnel is not feasible, the vessel will utilize a grab-equipped ROV to lift the cable after it is uncovered by a controlled flow excavator. The controlled flow excavator will solely utilize water jets to uncover the OoS cable. The cable removal vessel will also have a “clump weight” loaded aboard at a U.S. port. The vessel will attach the clump weight to the end of the remaining OoS cable on the seabed to ensure it remains in place and does not interfere with inter-array cable installation. The OoS cables to be removed from the seabed will consist solely of abandoned telecommunications cables.
Second, prior to cable laying operations, a vessel will drag a grapnel along the cable route several times, picking up debris from the seabed to include abandoned fishing nets and discarded rope. Grapnels will periodically be brought on board the vessel where debris will be removed and stored aboard the vessel. In the event any debris recovered from the seabed of the OCS is transported from these OCS seabed locations to a U.S. port, it will be transferred to a coastwise-qualified vessel beforehand. Finally, a survey vessel will use a multi-beam survey tool to map the seabed and anything that may lay on the seabed. The survey tool will not physically contact the seabed.
With regards to each of the three vessels above, your client has yet to determine whether to utilize a coastwise-qualified, or non-coastwise-qualified vessel. Additionally, each vessel may pick up as many as [ ] crew members at a U.S. port on the eastern seaboard and offload them at a different U.S. port on the eastern seaboard upon the completion of work. The crew members are likely to consist of a [ ].
Once seabed preparatory work is complete, the inter-array cable will be laid by the CIV by paying it out directly onto the seabed. A cable protection system (“CPS”) will also be installed. The CPS consists of a bend restrictor at the entry of the wind towers and a segmented tubular protection sleeve to protect the cable in the transition between wind tower entry above seabed level and complete burial. The CPS will be picked up along with the cable either at a U.S. port or a foreign port, stored in containers. Prior to the laying of the cable, the CPS will be attached to the cable onboard the CIV; thus the CPS will be paid out from the vessel along with the cable. The CIV may lay cable in stages, returning to a U.S. port to pick up additional cable. The empty CPS containers may be offloaded at a U.S. port other than the port from which it was laded. The CIV would recover the previously laid cable end from the seabed and join it to the new segment of cable to be laid.
Once cable laying operations are complete, there is a possibility excess cable originally laded aboard the CIV in a U.S. port will be either (i) unloaded from the CIV at the same berth in the same U.S. port where it was originally loaded, or (ii) unloaded from the CIV at a different port if the amount of excess cable is determined to be de minimis.
After the cable has been laid, it will be buried using a tracked underwater remotely operated vehicle (“ROV”). Your client is contemplating using one of four ROV models to complete this burial. The [ ] and the [ ] would [
]. On the other hand, the [
] would utilize [
]. The fourth model, the [ ] utilizes solely a [ ] for burial. Each ROV is capable of creating a slice into the seabed [ ] deep and [
] wide, and simultaneously buries the cable while trenching the seabed. None of the ROVs utilize a plough or hoe-type mechanism.
ISSUES
Whether transportation of subsea power cable from a foreign or a U.S. port by a foreign vessel, as described above, prior to cable lay operations would violate the Jones Act, 46 U.S.C. § 55102.
Whether the use of a foreign vessel to lay subsea power cable, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
Whether the return of a de minimis amount of excess power cable by a foreign cable installation vessel to the exact location from which it was laden, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
Whether the transportation of a de minimis amount of excess power cable by a foreign cable installation vessel between U.S. ports, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
Whether the employment by a foreign vessel of a pure chain cutting device, a hybrid water jet/chain cutter device, or a pure water jet device on the OCS seabed to bury subsea power cable, as described above, would violate the Dredging Statute, 46 U.S.C. § 55109.
Whether the use of a foreign vessel to engage in a pre-lay grapnel removal of out of service cable and debris, as described above, and subsequent transportation of such cable and debris to a U.S. port for recycling by a coastwise qualified vessel would violate the Dredging Statute, 46 U.S.C. § 55109.
Whether the transportation of containers containing cable protection materials between two U.S. ports by a foreign cable installation vessel, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
Whether the use of a foreign vessel to conduct survey operations, as described above, would violate the coastwise laws.
Whether the transportation of marine crew personnel between points in the United States by a foreign cable installation vessel, out of service cable removal vessel, pre-lay grapnel run vessel, and survey vessel, as described above, would violate the Passenger Vessel Services Act, 46 U.S.C. § 55103.
LAW AND ANALYSIS
The coastwise law applicable to the transportation of merchandise, known as the Jones Act, is found at 46 U.S.C. § 55102, and provides in pertinent part:
Except as otherwise provided in this chapter or chapter 121 of this title, a vessel may not provide any part of the transportation of merchandise by water, or by land and water, between points in the United States to which the coastwise laws apply, either directly or via a foreign port, unless the vessel—
is wholly owned by citizens of the United States for purposes of engaging in the coastwise trade; and
has been issued a certificate of documentation with a coastwise endorsement under chapter 121 or is exempt from documentation but would otherwise be eligible for such a certificate and endorsement.
The coastwise laws generally apply to points in the territorial sea, which is defined as the belt, three nautical miles wide, seaward of the territorial sea baseline, and to points located in internal waters, landward of the territorial sea baseline. 33 CFR § 2.22(a)(2). In addition, Section 4(a)(1) of the Outer Continental Shelf Lands Act of 1953 (“OCSLA”), as amended, provides that the Constitution and laws and civil and political jurisdiction of the United States are extended to:
the subsoil and seabed of the outer Continental Shelf;
all artificial islands on the outer Continental Shelf;
installations and other devices permanently or temporarily attached to the seabed, which may be erected thereon for the purpose of exploring for, developing, or producing resources, including non-mineral energy resources; or
any such installation or other device (other than a ship or vessel) for the purpose of transporting or transmitting such resources.
(Emphasis added).
Accordingly, the OCSLA, as amended in 2021, extends U.S. jurisdiction to devices attached to the seabed of the OCS for the purpose of producing non-mineral energy such as wind energy.
Pursuant to 46 U.S.C. § 55109, only coastwise-qualified vessels may engage in dredging in the navigable waters of the United States, which provides, in pertinent part:
[A] vessel may engage in dredging in the navigable waters of the United States only if— (1) the vessel is wholly owned by citizens of the United States for purposes of engaging in the coastwise trade; (2) the charterer, if any, is a citizen of the United States for purposes of engaging in the coastwise trade; and (3) the vessel has been issued a certificate of documentation with a coastwise endorsement under chapter 121 of this title or is exempt from documentation but would otherwise be eligible for such a certificate and endorsement.
Dredging is defined as “excavation” by any means:
The word “excavate” is derived from the Latin word meaning to hollow out. Its common, plain and ordinary meaning is to make a cavity or hole in, to dig out, hollow out, to remove soil by digging, scooping out or other means. The common plain and ordinary meaning of the word “dredging” is the removal of soil from the bottom waters by suction or scooping or other means.
Pursuant to 46 U.S.C. § 55103 (“the Passenger Vessel Services Act” or PVSA), only coastwise-qualified vessels may transport passengers between ports or places in the United States, providing in the pertinent part:
Except as otherwise provided in this chapter or chapter 121 of this title, a vessel may not transport passengers between ports or places in the United States to which the coastwise laws apply, either directly or via a foreign port, unless the vessel-
(1) wholly owned by U.S. citizens; and
(2) has a certificate of documentation with a coastwise endorsement.
The coastwise laws apply to the United States, including U.S. island territories and possessions, except for American Samoa, the Northern Mariana Islands, and the Virgin Islands. A non-coastwise-qualified vessel transporting passengers embarking from a U.S. port must disembark them at the same U.S. port in order to avoid a violation of 46 U.S.C. § 55103.
A passenger is defined under 46 U.S.C. § 55103 and 19 C.F.R. § 4.50(b) as “any person carried on a vessel who is not connected with the operation of such vessel, her navigation, ownership, or business.” Furthermore, the shipboard activities engaged in by such aforementioned individuals while traveling on a non-coastwise-qualified vessel between coastwise ports must be “directly and substantially” related to the operation, navigation, ownership, or business of the vessel itself in order for such individuals to not be considered as passengers under these provisions of law.
Issue One: Whether transportation of subsea power cable from a foreign or a U.S. port by a foreign vessel, as described above, prior to cable lay operations would violate the Jones Act, 46 U.S.C. § 55102
Prior to lading the inter-array cable aboard the CIV, your client notes the cable may be transported from a foreign port to a U.S. port by a non-coastwise-qualified foreign vessel. Here, the merchandise is being laden at a foreign point (the foreign port) and unladen at a coastwise point (the U.S. port). Because 46 U.S.C. § 55102 only applies to the transportation of merchandise between two coastwise points, the proposed transportation would not violate the Jones Act.
Issue Two: Whether the use of a foreign vessel to lay subsea power cable, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
CBP has long held that the sole use of a vessel in laying pipe or cable between two coastwise points is not considered a use in the coastwise trade of the United States. In doing so, CBP has reasoned that situations in which material is not landed as cargo but is only paid out in the course of the installation operation makes such operation permissible (i.e., “paid out/not unladen”). Further, since the use of a vessel in pipe or cable laying is not a use in the coastwise trade, a non-coastwise-qualified vessel may carry pipe or cable which is laid between such points by that vessel. A cable may be paid out with cable protection systems already attached to the cable without violating the coastwise laws. However, the transportation of pipe or cable by any vessel other than the vessel that is laying pipe to a pipe-laying location at a point within U.S. territorial waters would be considered coastwise trade and would therefore have to be accomplished by a vessel meeting the statutory requirements entitling it to engage in such trade.
In the present matter, your client proposes loading inter-array cable aboard the non-coastwise-qualified CIVs either at a U.S. port or a foreign port and paying out the cable directly onto the seabed at OCS sites outside U.S. territorial waters. The cable will be paid out with a cable protection system already attached to the cable. Although the cable may be laden at a coastwise point, the cable is paid out/not unladen onto the seabed. Therefore, the proposed scenario would not be in violation of the Jones Act, 46 U.S.C. § 55102.
Issue Three: Whether the return of a de minimis amount of excess power cable by a foreign cable installation vessel to the exact location from which it was laden, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
Your client proposes a scenario in which inter-array cable is laden aboard the non-coastwise-qualified CIV at a U.S. port prior to cable lay operations. Upon the completion of cable lay operation, excess cable would be returned by the CIV to the same location where it was originally laden. CBP has consistently held that there is no transportation of merchandise where merchandise is unladen from a vessel at the same location where it was originally laden. Because your client proposes unlading the excess cable at the “exact location” where it was originally laden aboard the CIV, no transportation of merchandise would occur and the proposed scenario would not be in violation of the Jones Act, 46 U.S.C. § 55102.
Issue Four: Whether the transportation of a de minimis amount of excess power cable by a foreign cable installation vessel between U.S. ports, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
Your client proposes an alternative scenario in which inter-array cable is laden aboard the non-coastwise qualified CIV at a U.S. port prior to cable lay operations. Upon the completion of cable lay, a de minimis amount of excess cable would be unladen by the CIV at a different U.S. port.
CBP has historically ruled that up to 5% of cable laden on a non-coastwise qualified vessel may be laden at one coastwise point and unladen at a second coastwise point without violating the Jones Act. In line with these existing rulings, there would be no violation of 46 U.S.C. § 55102 if the “de minimis” amount of excess cable unladen by the CIV at the second U.S. port is 5% or less of the cable laden aboard the CIV at the first U.S. port. Conversely, the unlading of more than 5% of the cable initially laden aboard the CIV would result in a violation of the Jones Act.
Issue Five: Whether the employment by a foreign vessel of a pure chain cutting device, a hybrid water jet/chain cutter device, or a pure water jet device on the OCS seabed to bury subsea power cable, as described above, would violate the Dredging Statute, 46 U.S.C. § 55109.
Once the CIV has laid the cable, your client contemplates utilizing a foreign vessel to bury the cable.
Pursuant to 46 U.S.C. § 55109(a), only coastwise-qualified vessels may engage in dredging in the navigable waters of the United States, providing, in pertinent part:
[A] vessel may engage in dredging in the navigable waters of the United States only if—
(1) the vessel is wholly owned by citizens of the United States for purposes of
engaging in the coastwise trade;
(2) the charterer, if any, is a citizen of the United States for purposes of
engaging in the coastwise trade; and
(3) the vessel has been issued a certificate of documentation with a coastwise endorsement under chapter 121 of this title or is exempt from documentation but would otherwise be eligible for such a certificate and endorsement
CBP has consistently held the term “navigable waters of the United States” to include the territorial sea of the United States, and internal waters. The territorial sea is defined as the belt, three nautical miles wide, seaward of the territorial sea baseline, and to points located in internal waters, landward of the territorial sea baseline. The territorial sea does not encompass points on the OCS more than three nautical miles from shore.
Dredging is defined as “excavation” by any means:
The word “excavate” is derived from a latin (sic.) word meaning to hollow out. Its common, plain and ordinary meaning is to make a cavity or hole in, to dig out, hollow out, to remove soil by digging, scooping out, or other means. The common plain and ordinary meaning of the word “dredging” is the removal of soil from the bottom waters by suction or scooping or other means.
CBP (to include its predecessor, the U.S. Customs Service) has consistently held that the term “dredging” within the meaning of 46 U.S.C. § 55109, is “the use of a vessel equipped with excavating machinery in digging up or otherwise removing submarine material.” See HQ 103692 (Dec. 28, 1978), published as Customs Service Decision (C.S.D.) 79-331; HQ 109910 (Jan. 26, 1989), published as C.S.D. 89-64.
However, CBP has consistently held that the use of certain devices to create underwater trenches for the purpose of cable laying does not constitute “dredging.” In particular, CBP has stated that the use by cable-laying vessels of cable-burial devices employing a jetting action resulting in the emulsification of the seabed, temporarily displacing sediment, surrounding the cable does not constitute an engagement in dredging. See, e.g., HQ 109412 (March 29, 1988), published at C.S.D. 88-7; HQ 109882 (Dec. 2, 1988); HQ 115646 (Apr. 12, 2002); HQ 115972 (Apr. 22, 2003); HQ 116117 (Feb. 26, 2004); HQ H311602 (Mar. 25, 2022); HQ H300962 (Apr. 14, 2022). Furthermore, CBP has also determined that the use of “a share or plow and cutting disc” that creates “a very narrow ‘slice” of the seabed under which the cable is buried is not an engagement in dredging.” See, e.g., HQ 113223 (Sept. 29, 1994) (relating to the use of an underwater trencher digging a 300 mm width trench) (citing to HQ 109412 (Mar. 29, 1988), published as C.S.D. 88-7). Specifically, CBP has reasoned that the use of a jetting tool to temporarily lift a “narrow ‘slice’” of the seabed amounts to a “temporary manipulation of the seabed” as opposed to the creation of a furrow or trench by operation of a share or plow and disc cutting wheel. See HQ 109412 (Mar. 29, 1988), published at C.S.D. 88-7. As such, this process is not considered “dredging” within the meaning of 46 U.S.C. § 55109.
Here, your client contemplates the use of pure chain cutting device, a hybrid water jet/chain cutter device, or a pure water jet device to conduct trenching and simultaneous burial of cable. CBP has previously held the use of each of these devices for trenching and burial activities not to be dredging, because each device only manipulates the seabed temporarily. Accordingly, your client’s use of each of these devices to bury cable would not constitute “dredging” for the purposes of the Dredging Statute.
Issue Six: Whether the use of a foreign vessel to engage in a pre-lay grapnel removal of out-of-service cable and debris, as described above, and subsequent transportation of such cable and debris to a U.S. port for recycling by a coastwise-qualified vessel would violate the Dredging Statute, 46 U.S.C. § 55109.
As discussed above, the Dredging Statute, 46 U.S.C. § 55109, prohibits the use of a non-coastwise qualified vessel to engage in dredging in the navigable waters of the United States.
CBP has previously held that the use of a pre-lay grapnel to remove OoS cable not to be “dredging”, inasmuch as the subject grapnels are not excavation equipment used for digging up of removing submarine material. Accordingly, your client’s use of a pre-lay grapnel would not be “dredging” for the purposes of the Dredging Statute.
With regards to the transportation of the clump weight by a non-coastwise qualified vessel from a U.S. or foreign port to telecommunications cables on the OCS, we note that no violation of the coastwise laws would occur because the out-of-service telecommunication cables are not coastwise points under OCSLA, inasmuch as the out-of-service telecommunications cables are not attached to the seabed for the purpose of exploring for, developing, or producing resources. Furthermore, the requestor states that any transportation of out-of-service cable from the high seas to a U.S. port will be conducted utilizing a coastwise-qualified vessel. Therefore, such transportation would not be violative of the coastwise laws.
Issue Seven: Whether the transportation of containers containing cable protection materials between two U.S. ports by a foreign cable installation vessel, as described above, would violate the Jones Act, 46 U.S.C. § 55102.
Your client proposes lading containers containing cable protection materials aboard the CIV at a U.S. port. During cable lay operations, the cable protection materials will be attached to the inter-array cable before it is paid out. Once cable lay is complete, the CIV may return to a different U.S. port with the empty containers.
CBP has held that “vessel equipment” or “equipment of the vessel” is not included within the general meaning of merchandise for purposes of the Jones Act. “Vessel equipment” has been defined as portable articles, “necessary and appropriate for the navigation, operation or maintenance of the vessel and for the comfort and safety of the persons on the board.” CBP has previously ruled empty containers used to carry wind turbine generator components are considered vessel equipment because they were necessary and appropriate to a wind turbine installation vessel’s function of installing wind turbine generators. Similarly, here the empty cable protection material containers are integral to the CIV’s cable lay operations. Therefore, the empty containers are considered vessel equipment, not merchandise, and the contemplated transportation would not be violative of the Jones Act, 46 U.S.C. § 55102.
Issue Eight: Whether the use of a foreign vessel to conduct survey operations, as described above, would violate the coastwise laws.
Your client proposes utilizing a foreign-flagged survey vessel to map seabed located in U.S. territorial waters and on the OCS. The survey vessel will utilize a multi-beam survey tool, which is sonar based and will not physically contact the seabed. Such an employment would not implicate either the Dredging Statute, 46 U.S.C. § 55109, or the Jones Act, 46 U.S.C. § 55102, therefore the use of a foreign-flagged vessel would be permissible.
Issue Nine: Whether the transportation of marine crew personnel between points in the United States by a foreign cable installation vessel, out-of-service cable removal vessel, pre-lay grapnel run vessel, and survey vessel, as described above, would violate the Passenger Vessel Services Act, 46 U.S.C. § 55103.
Your client contemplates utilizing four different non-coastwise-qualified vessels which may potentially transport crewmembers between different U.S. ports.
With regard to the out-of-service cable removal vessel, pre-lay grapnel run vessel, and survey vessel, each of which will be utilized for seabed preparatory works, you indicate that each vessel may pick up as many as [ ] crew members in a U.S. port, and offload them in a different U.S. port upon the completion of work. The crew members are likely to consist of a [
].
With regards to the CIV, it will be crewed by marine crew and project crew who will perform all the functions associated with installing the power cable including project developer representatives who board the CIV to perform project oversight and inspection functions. The CIV may potentially embark these personnel at a U.S. port where the cable is laden and disembark them at a different U.S. port once cable lay operations are complete.
In accordance with previous CBP rulings, individuals transported between coastwise points are not classified as “passengers” within the meaning of 46 U.S.C. § 55103 and 19 CFR § 4.50(b) if they are required to be onboard to contribute to the accomplishment of the operation or navigation of the vessel during the voyage or are onboard because of a necessary vessel ownership or business interest during the voyage. We have previously determined that cable installation vessel crew members directly and substantially connected with the laying of submarine electric transmission cables are not considered “passengers” within the meaning of 46 U.S.C. § 55103 and 19 CFR § 4.50(b). The determination extends to both marine crew, responsible for operating the vessel, and project crew, responsible for cable installation tasks.
With regards to the four vessels above, the [
] aboard the seabed preparatory vessels and the marine crew and project crew aboard the CIVs all perform functions related to the operation or navigation of the vessel. Therefore, they are not classified as “passengers”, and the proposed operations would not violate the Passenger Vessel Services Act, 46 U.S.C. § 55103.
HOLDING
The transportation of subsea power cable from a foreign or a U.S. port by a foreign vessel, as described above, prior to cable lay operations as described above would not violate the Jones Act, 46 U.S.C. § 55102.
The use of a foreign vessel to lay subsea power cable, as described above, would not violate the Jones Act, 46 U.S.C. § 55102.
The return of a de minimis amount of excess power cable by a foreign cable installation vessel to the exact location from which it was laden, as described above, would not violate the Jones Act, 46 U.S.C. § 55102.
The transportation of a de minimis amount of excess power cable by a foreign cable installation vessel between U.S. ports, as described above, would not violate the Jones Act, 46 U.S.C. § 55102 so long as the de minimis amount of cable consists of 5% or less of the cable initially laded aboard the vessel. The transportation of more than 5% of cable would violate the Jones Act.
The employment by a foreign vessel of a pure chain cutting device, a hybrid water jet/chain cutter device, or a pure water jet device on the OCS seabed to bury subsea power cable on the Outer Continental Shelf, as described above, would not violate the Dredging Statute, 46 U.S.C. § 55109.
The use of a foreign vessel to engage in a pre-lay grapnel removal of out-of-service communications cable and debris, as described above, would not violate the Dredging Statute, 46 U.S.C. § 55109. The subsequent transportation of out-of-service cable and debris removed from the seabed from an OCS location to a U.S. port utilizing a coastwise-qualified vessel would not violate the coastwise laws. .
The transportation of containers containing cable protection materials between two U.S. ports by a foreign cable installation vessel, as described above, would not violate the Jones Act, 46 U.S.C. § 55102.
The use of a foreign vessel to conduct survey operations, as described above, would not violate the coastwise laws.
The transportation of marine crew personnel between points in the United States by a foreign cable installation vessel, out of service cable removal vessel, pre-lay grapnel run vessel, and survey vessel, as described above, would not violate the Passenger Vessel Services Act, 46 U.S.C. § 55103.
Sincerely,
W. Richmond Beevers
Chief
Cargo Security, Carriers and Restricted Merchandise Branch
Office of Trade, Regulations and Rulings
U.S. Customs and Border Protection