Import Compliance Assistance Service being converted to an hourly charge rather
than a flat rate charge. This would certainly provide flexibility in charging and
make it easier for VS to recover costs when assisting importers. However, it adds
burden to the VS staff to monitor their time for each shipment to charge accurately
at an hourly rate. It has been my experience that correctly calculating time for a
task that is done while in an office where you are simultaneously conducting other
tasks can be very challenging. VS might find that undercharging with an hourly
rate ends up recovering less cost than currently recovered with a flat rate.
Comment from Rosemary Sifford
This is comment on Proposed Rule
Import/Export User Fees
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