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October 2025, question 67
Valuation, Appraisement and Duty Assessment · Valuation
An Irish golf accessory manufacturer, acting as the importer of record, imports golf balls to give away as a promotion at a tournament it is sponsoring. Because there is no sale at the time of import, what value must be listed on the invoice?
- The value calculated based on the manufacturer's average shipment value for the last 12 months.
- The highest value the manufacture has received for the sale of similar goods.
- There is no value because there is no sale.
- The value as if the manufacturer sold the golf balls to an importer in the ordinary course of trade.

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CBP's answer: D. D: The value as if the manufacturer sold the golf balls to an importer in the ordinary course of trade.
Section 141.86(a)(6) says that for merchandise shipped other than under a sale, the invoice states the value for each item or, absent that, the price the manufacturer or shipper would have received if sold in the ordinary course of trade and in the usual wholesale quantities in the country of exportation. The promotional golf balls are not sold, so the as-if-sold value is listed (D).
the price in such currency that the manufacturer, seller, shipper, or owner would have received, or was willing to receive, for such merchandise if sold in the ordinary course of trade 19 CFR 141.86(a)(6)
Search for: shipped otherwise than in pursuance of a purchase or an agreement to purchase
CBP's key cites: 19 CFR 141.86(a)(6); 19 CFR 152.101(b)
Question and key from CBP's October 2025 exam and answer key. The walk-through is ours; quotes are from the pinned editions in the reference viewer (HTSUS 2026 Basic, 19 CFR 2025 edition).