Registering a Vessel as British in the US

[Vasco]

Originally Posted by boatpoker

Not true ... The foreign flagged vessel must leave the country, not the person.

Like beating a dead horse but I will state it again. If a non-citizen resident of the US has a foreign flagged vessel in the US, he/she can get a new permit on expiry of the permit without the boat having to leave the US. I have discussed this with the authorities. When discussing this issue it is important to talk to someone who understands the regulations. I have found many of the CBP officers lack a comprehensive understanding of the regulations.

"Under CBP policy, non-U.S. residents are not eligible for successive cruising licenses. A new license will not be issued unless the following two conditions have been met: (1) at least 15 days have elapsed since the previous license either expired or was surrendered, and (2) the vessel arrives in the U.S. from a foreign port or place. (Customs Directive 3130-006A) CBP will want to see foreign clearance paperwork as evidence that you are arriving from a foreign location."

The above clearly states "non-US residents are not eligible for successive cruising licenses". US residents (non-citizens with green cards) can get successive cruising licenses.

[boatpoker]

Originally Posted by Vasco

Like beating a dead horse but I will state it again. If a non-citizen resident of the US has a foreign flagged vessel in the US, he/she can get a new permit on expiry of the permit without the boat having to leave the US. I have discussed this with the authorities. When discussing this issue it is important to talk to someone who understands the regulations. I have found many of the CBP officers lack a comprehensive understanding of the regulations.

"Under CBP policy, non-U.S. residents are not eligible for successive cruising licenses. A new license will not be issued unless the following two conditions have been met: (1) at least 15 days have elapsed since the previous license either expired or was surrendered, and (2) the vessel arrives in the U.S. from a foreign port or place. (Customs Directive 3130-006A) CBP will want to see foreign clearance paperwork as evidence that you are arriving from a foreign location."

The above clearly states "non-US residents are not eligible for successive cruising licenses". US residents (non-citizens with green cards) can get successive cruising licenses.

The above clearly states no such thing and again the license is tied to the boat not the crew. Having travelled under dozens of "permissions to proceed" and "cruising licenses" delivering boats owned by a number of nationalities. I think I'll rely on my own experiences regardless of blind or dead horses. Have at it, i'm done.

[boatman61]

Originally Posted by boatpoker

Not true ... The foreign flagged vessel must leave the country, not the person.

Not according to CG&C in Morehead City.. my Hunter with Brit flag could stay in the States till Hell freezes over whereas I merely had 90 days.
As things turned out she stayed in NC for close on 18mths after I bought and reflagged her.

[Montanan]

Originally Posted by boatpoker

Unless they are built in NAFTA (USMCA) countries.

The USMCA agreement, if approved, will become effective in 2020, until then NAFTA applies.

Canada implemented a 10% retaliatory tariff on import of US built boats effective July 1, 2018 this tariff is in response to the US imposing Section 232 tariffs on steel [25%] and aluminum [10%] and likely will remain in effect until the US tariffs on steel and aluminum are removed.

The General US tariff on sailboats is 1.5%. There are eighteen countries to which a "Special" US tariff rate applies, which rate is duty Free. Canada and Mexico are included in the eighteen countries.

[Montanan]

FYI. Copied below is the relevant US customs directive as to issuance of successive cruising licenses. Read and interpret as you may.

Copied further below are the relevant section of the Code of Federal Regulations [CFR]

CUSTOMS DIRECTIVE

ORIGINATING OFFICE: FO:P DISTRIBUTION: S-01
CUSTOMS DIRECTIVE NO. 3130-006A
DATE: MAY 20, 1999
SUPERSEDES: 3130-006, 11/7/88
REVIEW DATE: MAY 2001

SUBJECT: Issuance of Successive Cruising Licenses; Definition of
"Undocumented American Pleasure Vessel"

1 PURPOSE. To clarify the circumstances in which a foreign-owned pleasure
vessel may be issued successive Cruising Licenses and to define the term
"undocumented American pleasure vessel."

2 POLICY. It has been the policy of the Customs Service not to issue
successive Cruising Licenses for a pleasure vessel except under special
circumstances (e.g., for a pleasure vessel brought in to the United States by a
foreign diplomat or a person representing a foreign country at an international
organization headquartered in the United States, during the tour of that
diplomat or person in the United States).

3 AUTHORITIES/REFERENCES. Sections 434, 435, and 441, Tariff Act of 1930,
as amended (19 USC 1434, 1435, and 1441); Section 5, Act of May 28, 1908, as
amended (35 Stat. 425; 46 USC App. 104) and Sections 4197 and 4214; Revised
Statutes, as amended (46 USC App. 91 and 103); Sections 4.3, 4.60(b)(3), and
4.94, Customs Regulations (19 CFR 4.3, 4.60(b)(3), and 4.94); Section 3111.17 of
the Carrier Control Handbook (Vessels) (HB 3100-02), issued July 31, 1981;
Items 8903.91, 8903.92, and 8903.99.20 of the Harmonized Tariff Schedule of the
United States.
.
4 DEFINITIONS.

4.1 The term "licensed yacht or undocumented American pleasure vessel" in 19
USC 1441(3) and 46 USC App. 91, under which such vessels are exempt from vessel
entry and clearance under the circumstances described therein, shall be
interpreted as follows:

4.2 A "licensed yacht or undocumented American pleasure vessel" includes:

4.2.1 A pleasure vessel documented by the United States Coast Guard under 46 USC
Chapter 121; and an undocumented pleasure vessel owned by a citizen of the
United States, regardless of whether the United States citizen is a resident of
the United States and regardless of whether the vessel is numbered under a State
numbering system.

4.3 A "licensed yacht or undocumented American pleasure vessel" does not
include:


4.3.1 A pleasure vessel documented under a foreign flag, regardless of whether
it is owned by a citizen of the United States and regardless of whether it is
numbered under a State numbering system and an undocumented pleasure vessel
owned by a foreign citizen, regardless of whether it is numbered under a State
numbering system.

5 RESPONSIBILITIES.

5.1 Principal Field Officers (PFO), which include the Port Directors, are
responsible for the overall policy implementation and reliability of this
program.

5.2 Chief Inspectors (or their equivalent) shall manage the implementation of
this policy.

5.3 Supervisors will be responsible for assuring adherence to this directive.

6 PROCEDURES.

6.1 In the interest of uniformity, Cruising Licenses for pleasure vessels
owned by resident aliens shall be issued to:

6.1.1 Foreign-documented pleasure vessels which were built in the United States
or upon which duty has been paid.

6.1.2 Successive Cruising Licenses may be issued to a foreign-documented
pleasure vessels which were built in the United States or on which United States
Customs duty has been paid, provided, that the vessel is documented under the
laws of one of the countries listed in 19 CFR 4.94(b).

6.1.3 Other foreign-documented pleasure vessels. Except in the special
circumstances described in the POLICY portion of this Directive, a foreign-
documented pleasure vessel which was not built in the United States and upon
which United States Customs duty has not been paid shall not be issued
successive Cruising Licenses.

6.2 Upon expiration of one Cruising License, such a pleasure vessel shall not
be entitled to another one until it again arrives in the United States from a
foreign port or place and more than 15 days have elapsed since the expiration of
the vessel's previous Cruising License.

6.3 Customs officers should be aware that a foreign-documented pleasure vessel
which is kept in the United States by a nonresident thereof is not subject to
United States Customs duty, regardless of whether it has a Cruising License,
provided, of course, that the vessel is not sold or chartered, or offered for
sale or charter, to a resident of the United States.

7 MEASUREMENTS.

7.1 The number of successive cruising licenses issued.




Assistant Commissioner
Office of Field Operations

§ 4.94 Yacht privileges and obligations.
(a) Any documented vessel with a pleasure license endorsement, as well as any undocumented American pleasure vessel, shall be used exclusively for pleasure and shall not transport merchandise nor carry passengers for pay. Such a vessel which is not engaged in any trade nor in any way violating the Customs or navigation laws of the U.S. may proceed from port to port in the U.S. or to foreign ports without clearing and is not subject to entry upon its arrival in a port of the U.S., provided it has not visited a hovering vessel, received merchandise while in the customs waters beyond the territorial sea, or received merchandise while on the high seas. Such a vessel shall immediately report arrival to Customs when arriving in any port or place within the U.S., including the U.S. Virgin Islands, from a foreign port or place.

(b) A cruising license may be issued to a yacht of a foreign country only if it has been made to appear to the satisfaction of the Secretary of the Treasury that yachts of the United States are allowed to arrive at and depart from ports in such foreign country and to cruise in the waters of such ports without entering or clearing at the customhouse thereof and without the payment of any charges for entering or clearing, dues, duty per ton, tonnage, taxes, or charges for cruising licenses. It has been made to appear to the satisfaction of the Secretary of the Treasury that yachts of the United States are granted such privileges in the following countries:

Argentina
Australia
Austria
Bahama Islands
Belgium
Bermuda
Canada
Denmark
Finland
France
Germany, Federal Republic of
Greece
Honduras
Ireland
Italy
Jamaica
Liberia
Marshall Islands
Netherlands
New Zealand
Norway
Saint Kitts and Nevis
Saint Vincent and the Grenadines
Sweden
Switzerland
Turkey
United Kingdom and the Dependencies: the Anguilla Islands, the Isle of Man, the British Virgin Islands, the Cayman Islands, and the Turks and Caicos Islands
(c) In order to obtain a cruising license for a yacht of any country listed in paragraph (b) of this section, there shall be filed with the port director an application therefor executed by either the yacht owner or the master which shall set forth the owner's name and address and identify the vessel by flag, rig, name, and such other matters as are usually descriptive of a vessel. The application shall also include a description of the waters in which the yacht will cruise, and a statement of the probable time it will remain in such waters. Upon approval of the application, the port director will issue a cruising license in the form prescribed by paragraph (d) of this section permitting the yacht, for a stated period not to exceed one year, to arrive and depart from the United States and to cruise in specified waters of the United States without entering and clearing, without filing manifests and obtaining or delivering permits to proceed, and without the payment of entrance and clearance fees, or fees for receiving manifests and granting permits to proceed, duty on tonnage, tonnage tax, or light money. The license shall be granted subject to the condition that the vessel shall not engage in trade or violate the laws of the United States in any respect. Upon the vessel's arrival at any port or place within the U.S. or the U.S. Virgin Islands, the master shall comply with 19 U.S.C. 1433 by immediately reporting arrival at the nearest Customs facility or other place designated by the port director. Individuals shall remain on board until directed otherwise by the appropriate Customs officer, as provided in 19 U.S.C. 1459.

(d) Cruising licenses shall be in the following form:

License To Cruise in the Waters of the United States
To Port Directors:
For a period of ____ from ____(Date) the ____(Flag) ____ (Rig) yacht ____(Name) belonging to ________ of (Owner's name) ________(Address) shall be permitted to arrive at and depart from the United States and to cruise in the waters of the Customs port of

(Name of port or ports)
without entering and clearing, without filing manifests and obtaining or delivering permits to proceed, and without the payment of entry and clearance fees, or fees for receiving manifests and granting permits to proceed, duty on tonnage, tonnage tax, or light money.
This license is granted subject to the condition that the yacht named herein shall not engage in trade or violate the laws of the United States in any respect. Upon arrival at each port or place in the United States, the master shall report the fact of arrival to the Customs officer at the nearest customhouse. Such report shall be immediately made.

Issued this _____ day of _______, 19__

(Port Director of Customs)
Warning: This vessel is dutiable:

(1) If owned by a resident of the United States (including Puerto Rico), or brought into the United States (including Puerto Rico), for sale or charter to a resident thereof, or

(2) If brought into the United States (including Puerto Rico) by a nonresident free of duty as part of personal effects and sold or chartered within one year from date of entry.

Any offer to sell or charter (for example, a listing with yacht brokers or agents) is considered evidence that the vessel was brought in for sale or charter to a resident or, if made within one year of entry of a vessel brought in free of duty as personal effects, that the vessel no longer is for the personal use of the non-resident.

If the vessel is sold or chartered, or offered for sale or charter, in the circumstances described, without the owner first having filed a consumption entry and having paid duty, the vessel may be subject to seizure or to a monetary claim equal to the value of the vessel. See Chapter 89, Additional U.S. Note 1, HTSUS, and subheadings 8903.10, 8903.91, 8903.92, 8903.99.10, 8903.99.20, and 8903.99.90, HTSUS.

(e) A foreign-flag yacht which is not in possession of a cruising license shall be required to comply with the laws applicable to foreign vessels arriving at, departing from, and proceeding between ports of the United States.

[T.D. 69-266, 34 FR 20423, Dec. 31, 1969]

46 USC Appendix 91 - Clearance; vessels
a) When required; vessels of United States
Except as otherwise provided by law, any vessel of the United States shall obtain clearance from the Customs Service before proceeding from a port or place in the United States
(1) for a foreign port or place;
(2) for another port or place in the United States if the vessel has on board foreign merchandise for which entry has not been made; or
(3) outside the territorial sea to visit a hovering vessel or to receive merchandise while outside the territorial sea.
b) When required; other vessels
Except as otherwise provided by law, any vessel that is not a vessel of the United States shall obtain clearance from the Customs Service before proceeding from a port or place in the United States
(1) for a foreign port or place;
(2) for another port or place in the United States; or
(3) outside the territorial sea to visit a hovering vessel or to receive or deliver merchandise while outside the territorial sea.
(c) Regulations
The Secretary of the Treasury may by regulation
(1) prescribe the manner in which clearance under this section is to be obtained, including the documents, data or information which shall be submitted or transmitted, pursuant to an authorized data interchange system, to obtain the clearance;
(2) permit the Customs Service to grant clearance for a vessel under this section before all requirements for clearance are complied with, but only if the owner or operator of the vessel files a bond in an amount set by the Secretary of the Treasury conditioned upon the compliance by the owner or operator with all specified requirements for clearance within a time period (not exceeding 4 business days) established by the Secretary of the Treasury; and
(3) authorize the Customs Service to permit clearance of any vessel to be obtained at a place other than a designated port of entry, under such conditions as he may prescribe.

19 U.S. Code § 1441 - Exceptions to vessel entry and clearance requirements . . .
(4) Any United States documented vessel with recreational endorsement or any undocumented United States pleasure vessel not engaged in trade, if—
(A) the vessel complies with the reporting requirements of section 1433 of this title, and with the customs and navigation laws of the United States;
(B) the vessel has not visited any hovering vessel; and
(C) the master of, and any other person on board, the vessel, if the master or such person has on board any article required by law to be entered or declared, reports such article to the Customs Service immediately upon arrival.

[jmschmidt]

This is such a simple subject, but there is so much misunderstanding, false and erroneous information and just made-up nonsense on this forum I don't know where to begin, so I won't.

[Montanan]

Originally Posted by Steven UK

Does Canadian count as US built? Probably a stupid question...

Answer. No a Canadian built boat is not a US built boat. The only issue that I perceive as to the distinction as for US regulations would be custom duty but Canadian boats are provided a "Special" tariff rate which is Duty Free.

[Montanan]

Originally Posted by Vasco

Like beating a dead horse but I will state it again. If a non-citizen resident of the US has a foreign flagged vessel in the US, he/she can get a new permit on expiry of the permit without the boat having to leave the US. I have discussed this with the authorities. When discussing this issue it is important to talk to someone who understands the regulations. I have found many of the CBP officers lack a comprehensive understanding of the regulations.

"Under CBP policy, non-U.S. residents are not eligible for successive cruising licenses. A new license will not be issued unless the following two conditions have been met: (1) at least 15 days have elapsed since the previous license either expired or was surrendered, and (2) the vessel arrives in the U.S. from a foreign port or place. (Customs Directive 3130-006A) CBP will want to see foreign clearance paperwork as evidence that you are arriving from a foreign location."

The above clearly states "non-US residents are not eligible for successive cruising licenses". US residents (non-citizens with green cards) can get successive cruising licenses.

Of relevance to Steven, if he desires to pursue the UK Small Ship Registry documentation route for avoiding state sales and use taxation, since he is a permanent resident of the US [Green Card holder, non-US citizen] seems to be part 6 and Part 4.3 of the Customs Directive.

6 PROCEDURES.

6.1 In the interest of uniformity, Cruising Licenses for pleasure vessels
owned by resident aliens shall be issued to:

6.1.1 Foreign-documented pleasure vessels which were built in the United States
or upon which duty has been paid.

6.1.2 Successive Cruising Licenses may be issued to a foreign-documented
pleasure vessels which were built in the United States or on which United States
Customs duty has been paid, provided, that the vessel is documented under the
laws of one of the countries listed in 19 CFR 4.94(b). The UK is on that list.

6.2 Upon expiration of one Cruising License, such a pleasure vessel shall not
be entitled to another one until it again arrives in the United States from a
foreign port or place and more than 15 days have elapsed since the expiration of
the vessel's previous Cruising License.

4.3 A "licensed yacht or undocumented American pleasure vessel" does not
include:

4.3.1 A pleasure vessel documented under a foreign flag, regardless of whether
it is owned by a citizen of the United States and regardless of whether it is
numbered under a State numbering system and an undocumented pleasure vessel
owned by a foreign citizen, regardless of whether it is numbered under a State
numbering system.

Steven asked about a Canadian built boat, if the boat is Canadian origin then duty will need to be paid in order to obtain successive cruising license. Albeit the duty is presently Free for imports of Canadian origin boats [I wouldn't put it past Trump to pursue a retaliatory tariff on Canadian boats as a response to Canada's 10% retaliatory tariff on USA origin boats imported to Canada. Tit for Tat seems to be the political will of late.

Also, per the terms of the US cruising license - This vessel is dutiable:

(1) If owned by a resident of the United States (including Puerto Rico).

Note, Steven is a resident of the United States but for now it would be Duty Free.


A new cruising license will only be issued if the following two conditions have been met:

At least 15 days have elapsed since the previous license either expired or was surrendered, and
The vessel arrives in the U.S. from a foreign port or place.

CBP will want to see foreign clearance paperwork as evidence that the vessel is arriving from a foreign location.

It is advisable for yacht owners to plan their cruising schedule carefully so that the mandatory 15-day period does not fall in the middle of a planned stay in U.S. waters. It is also sensible for yacht owners to surrender their cruising license to a CBP Officer when leaving U.S. waters for a foreign port so that a new licence can be applied for on re-entry to the U.S. It should be noted that traveling outside of U.S. waters while a cruising license is in effect does not fulfill the aforementioned 15-day requirement.

Hence it appears that the vessel will need to depart US waters and arrive from a foreign port or place. Steven should surrender the cruising license at time of departure and then reapply for a successive cruising license upon reentry to US waters after the 15 day period. Steven should not let the cruising license expire while his boat remains in the USA. As I read the regulations it can't just go out into international waters, it must enter a foreign country so as to arrive from a foreign port or place upon reentry. Steven, the owner being a permanent resident of the USA [Green Card Holder] can remain in the USA, only his vessel needs to depart the country to a foreign port or place.

I may be interpreting the regulations incorrectly. I am not an attorney that is familiar with these nuances of customs clearance and cruising licenses, but the above is my dead reckoning.

[anodyneGB]

Hi,

Done this for real :-) UK national, US resident, bought a US boat with USCG registration.

1) USCG documentation needs to be returned as you aren't a US citizen. The registration certificate was needed in step 2)
2) Got a UK part 1 registration as the SSR is only valid for people resident in the UK (anyone who says otherwise hasn't read the small print). Very efficient process mainly done online - the MSCA staff are very helpful. 125 quid for 5 years and renewable online after that. Only complication is getting a measurement certificate if you haven't got one, but it didn't take me long to get this organized (I can drop you the details of the firm I used - NB this can't be done by a normal surveyor)
3) Got a Cruising Licence - if your boat is US built then it DOES NOT need to leave the US for 15 days. The critical bit is the fact that the boat is 'US built' - foreign built boats do need to be out of the US for at least 15 days - note that this means you need proof of entry/exit from a foreign port - just going for an offshore sail isn't sufficient. I've now had mine renewed 4 times - just requires a visit to the CBP office one a year.
4) Fly the Red Ensign - CoastGuard, CBP and Police will be curious but no real issues once they've seen your passports, Registration and Cruising Licence. We get visited once a year to check on the papers - a formality now that they know the boat. Very friendly heavily armed officers. NB Once you are foreign flagged the boat only needs to conform to the flag regs not the US regs, but clearly it makes sense not to deliberately ignore them. However it is useful for example for things like lifejackets - it means we can use our UK ISO/BSI ones rather than having to purchase USCG ones.
5) Only real hassle is that you need to ring the local CBP everytime you move port even just on a short jaunt
6) The tender is a grey area - strictly it doesn't need to be registered because it belongs to the registered boat. However having State registration stops a lot of unnecessary hassle when the police stop you for not being registered (having all your papers onboard is a pain on a rubber dinghy!) - given the minimal cost I'd just write off a day and go to the DMV and get it registered separately.
7) Obviously if the boat ever goes home in all likelihood you will need to pay VAT

[Steven UK]

quick update... (i'll catch up on the latest posts over lunch time) i gave a call to the relevant authorities in the UK and sounds relatively easy to get the Part 1 registration. i cannot get the Part 3 or SSR registration because i'm not a resident. so it means 124gbp instead of ~30gbp. not a big deal but i will need a surveyor who has the necessary credentials to provide the certificate of Gross Tonnage. i think closest place will be FL from where i will likely be purchasing.

its starting to get exciting...

[boatpoker]

When you find the boat, let me know. If it is a standard production boat I have in my files, I can do a "sistership" measurement for you gratis. I am a Transport Canada Appointed Tonnage Measurer.

Explanation: A standard production vessel can be "sistership" measured by a recognized surveyor on approval of the flag state. I already have that recognition in the UK. If I have those measurements in my files it's no big deal to simply insert your personal information.

The measurements required have nothing to do with the measurements you are accustomed to dealing with other than breadth.

[Steven UK]

Looking at some of this info... firstly my aim is not to bypass any tax or duty payments I just want to own a boat and not be constrained to coast and cruising.

Of relevance to Steven, if he desires to pursue the UK Small Ship Registry documentation route for avoiding state sales and use taxation, since he is a permanent resident of the US [Green Card holder, non-US citizen] seems to be part 6 and Part 4.3 of the Customs Directive.

6 PROCEDURES.

6.1 In the interest of uniformity, Cruising Licenses for pleasure vessels
owned by resident aliens shall be issued to:

6.1.1 Foreign-documented pleasure vessels which were built in the United States
or upon which duty has been paid.

6.1.2 Successive Cruising Licenses may be issued to a foreign-documented
pleasure vessels which were built in the United States or on which United States
Customs duty has been paid, provided, that the vessel is documented under the
laws of one of the countries listed in 19 CFR 4.94(b). The UK is on that list.

6.2 Upon expiration of one Cruising License, such a pleasure vessel shall not
be entitled to another one until it again arrives in the United States from a
foreign port or place and more than 15 days have elapsed since the expiration of
the vessel's previous Cruising License.

So 6.1.2 and 6.2 seem to contradict each other, can someone enlighten me. Apologies for my ignorance. I have read it a couple of times and I can make it mean anything I want... it’s a 30 year old boat registered in the state of TX I’m sure the duty has been paid.

[Montanan]

Hi Steven:

As to successive cruising licenses it appears that your resident alien status may provide you with special treatment.

Reference.
Three Steps to Renew Your Cruising License - Howard S Reeder Inc

Yet the Customs Directive language at 6.2 appears to read differently then what is proscribed in the link above with regards to need to arrive from a foreign port or place.

Practice and policy may differ from regulatory language.

Suggest you call Customs at a port.

Not sure about State registration, cruising permits, taxation, with vessels operating under the USCBP cruising license.

[Steven UK]

Everyone thank you all very much, the more I learn the more questions I seem to have. But seems the first big hurdle is over.

[Montanan]

Steven, I failed to see the forest for the trees in regard to the construct of the Customs Directive.

6.1 In the interest of uniformity, Cruising Licenses for pleasure vessels
owned by resident aliens shall be issued to:

6.1.1 Foreign-documented pleasure vessels which were built in the United States
or upon which duty has been paid.

6.1.2 Successive Cruising Licenses may be issued to a foreign-documented
pleasure vessels which were built in the United States or on which United States
Customs duty has been paid, provided, that the vessel is documented under the
laws of one of the countries listed in 19 CFR 4.94(b). The UK is on that list.

6.2 Upon expiration of one Cruising License, such a pleasure vessel shall not
be entitled to another one until it again arrives in the United States from a
foreign port or place and more than 15 days have elapsed since the expiration of
the vessel's previous Cruising License.

Note that Section 6.1 is specific to pleasure vessels owned by resident aliens, of which you are one. Hence the subsections 6.1.1 and 6.1.2 apply.
Whereas, Section 6.2 is for vessels owned by other than those where Section 6.1 applies, that is to say, vessels owned by non-resident aliens.

You indicated that the boat you are purchasing was previously USCG documented [by an American citizen], hence you can assume duty was paid if any duty was applicable.

Me be like:

Happy sailing.