Expeditors International of Washington (EXPD) Status Update summary

Overview of DCMA Duty-Free Entry process

• DCMA Duty-Free Entry (DFE) allows DoD contractors to import eligible goods without paying customs duties, governed by DFARS 252.225-7013, which must be included in contracts for eligibility.

• DFE applies to end items, components, and supplies from qualifying countries, provided duties are not included in the contract price and estimated duty exceeds $300 per shipment.

• The process involves multiple agencies: DCMA, contracting officers, customs brokers, and U.S. Customs and Border Protection, each with defined roles.

• Entitlement requests are submitted via the PIEE platform by prime contractors, with brokers receiving tokenized emails to process certificates.

• Certificates must be uploaded to the Customs DIS system within six months of entry to avoid duty assessment.

Key process steps and requirements

• Prime contractors initiate entitlement requests in PIEE, listing the customs broker and providing required documentation.

• Contracting officers review entitlement requests within 20 days, and DCMA reviews certificate requests for completeness.

• Each entitlement is tied to a specific foreign supplier; multiple entitlements may be needed for shipments from multiple suppliers.

• Timing is critical: entitlement should be created as soon as a purchase order is placed, and certificates must be uploaded within six months.

• Required documents include commercial invoices and Customs Form 7501, both listing the DoD contract number and relevant details.

Best practices and common scenarios

• Ensure the DFARS DFE clause is in contracts and flowed down to subcontractors; maintain accurate and complete documentation.

• Communicate clearly with brokers and suppliers, and keep robust records of entitlements and certificates.

• Subcontractors must coordinate with primes for entitlement creation and ensure timely broker communication.

• DFE can be claimed for shipments with both commercial and government products, and for FTZ withdrawals, with some nuances.

• Post summary corrections are possible before liquidation, and entitlements should be created before importation.