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Valuation · CBLE study guide

Transaction value: statutory additions

Assists, commissions, royalties, packing, proceeds.

Common traps

Wrong answers on past exams cluster around a few beliefs. Here is each one, and what the rule actually says.

What is an assist

“Any design work or equipment supplied counts as an assist, even U.S. engineering.”

The rule: Assists include materials, tools/dies/molds, materials consumed, and foreign engineering/design/artwork. Engineering or design undertaken in the United States is not an assist.

Remember: Design work: assist only if done outside the U.S.

19 CFR 152.102(a)

Transaction value additions

“Buying commissions or U.S. inland freight are added.”

The rule: Transaction value is the price actually paid or payable plus packing costs, selling commissions, assists, royalties/license fees, and proceeds of resale accruing to the seller.

Remember: Five additions: packing, selling commission, assist, royalty, proceeds.

19 CFR 152.103(b)

When U.S.-performed engineering is excluded

“Any U.S.-performed design is excluded, regardless of who does it.”

The rule: Engineering work is not an assist only if performed by an individual domiciled in the U.S., acting as the buyer's employee or agent, incidental to U.S. engineering. Work by someone domiciled abroad may be an assist.

Remember: Domicile + buyer's employee/agent + U.S. context.

19 CFR 152.102(a)(2)

Buying vs. selling commissions

“All commissions are added, or none are.”

The rule: Selling commissions incurred by the buyer and indirect payments to the seller are added; bona fide buying commissions paid to the buyer's agent are not.

Remember: Whose agent? Buyer's agent = not added.

19 CFR 152.102(b) · 19 CFR 152.103(b)(1)

Apportionment of assists

“Allocating an assist is called proration, deduction or inclusion.”

The rule: Spreading or concentrating an assist's value across shipments is 'apportionment'; the whole value may go on the first shipment, be spread by units, or over anticipated production.

Remember: Apportionment.

19 CFR 152.103(e)

Royalties paid to third parties

“Any royalty connected to the product is added.”

The rule: A royalty is added only if the buyer must pay it, directly or indirectly, as a condition of the sale for export. A royalty the buyer later decides to pay a third party for its own products is not added.

Remember: Condition of sale? If not, don't add.

19 CFR 152.103(b)(1)(iv) · 19 CFR 152.103(f)

Try a past question

October 2026 CBLE, question 72

If engineering work is necessary for the production of the imported merchandise, it may be an assist for the purposes of appraisement in which ONE of the following scenarios?

AThe engineering work is performed under contract with the U.S. importer by an individual temporarily domiciled within the United States on assignment by his employer in the Netherlands.
BThe engineering work is performed under contract with the U.S. importer by an individual domiciled within the United States and works from home for a U.S.- based firm.
CThe engineering work is performed by an individual who resides in Ireland but is temporarily in the United States working as an employee of the U.S. importer.
DThe engineering work is performed by an individual domiciled in Canada who is a U.S. citizen and works for a U.S. firm under contract with the U.S. importer.
Show the answer and why

A. Incorrect. The individual is domiciled in the U.S., so the exclusion can apply.

B. Incorrect. U.S.-domiciled individual working for the buyer: excluded.

C. Incorrect. Working as the importer's employee in the U.S. on U.S. engineering: excluded.

D. Correct. Someone domiciled in Canada does not meet the U.S.-domicile condition, so the work may be an assist (19 CFR 152.102(a)(2)(i)).

19 CFR 152.102(a)(2) · law as of 2026-11-09

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