Administrative Law Keyed to Lawson
United States v. Mead
The Harmonized Tariff Schedule of the United States (HTSUS) had two categories for notebooks and related products: one category was subject to a 4% tariff, and the “other” category was free of duty. Customs had treated Mead’s day planners as falling under the duty-free category, but changed its position in a 1993 Headquarter ruling letter. Mead challenged the ruling and appealed up to the United States Court of Appeals for the Federal Circuit, which held that Customs’ rulings are not subject to notice and comment, do not carry the force of law, and are not entitled to Chevron deference.
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