Assists

Assists are items or services supplied directly or indirectly, free of charge or at reduced cost, by the U.S. buyer to the foreign seller for use in connection with the production or sale of the imported merchandise. Their apportioned value is a statutory addition to the price actually paid or payable when computing transaction value, under 19 U.S.C. § 1401a(h)(1)(A).

There are four categories of assists:

1. Materials, components, parts, and similar items incorporated in the merchandise
2. Tools, dies, and molds and similar items used in producing the merchandise
3. Merchandise consumed in producing the imported merchandise (e.g., fuel, lubricants)
4. Engineering, development, artwork, design work, and plans and sketches undertaken outside the United States and necessary for production

Engineering and design work performed in the United States is not an assist — this is a key carve-out. R&D conducted at the U.S. parent's facility and provided to a foreign manufacturer doesn't increase customs value.

The full value of an assist is its acquisition or production cost plus transportation to the place of production. That value is then apportioned across the units of merchandise it benefits — typically the entire production run that uses the assist, though the importer may use any reasonable method consistent with GAAP.

Missing an assist is one of the most common CBP audit findings. An unreported tooling charge of $200,000 spread across 100,000 units adds $2 per unit to customs value — and the unpaid duty plus interest, multiplied across years, can exceed the original assist value. Prior disclosure under § 1592(c)(4) is the standard remediation.