AgentSkillsCN

comply

提供国际贸易领域的监管合规情报，涵盖 PGA 要求（FDA、EPA、USDA、CPSC）、被拒名单筛查、制裁措施、出口管制以及进口文件要求。当有人咨询法规、许可证、执照、“我能否进口这件商品？”、合规要求、FDA 审批、制裁措施或受限主体相关事宜时，可参考本工具。

SKILL.md
--- frontmatter
name: comply
description: Regulatory compliance intelligence for international trade. Covers PGA requirements (FDA, EPA, USDA, CPSC), denied party screening, sanctions, export controls, and import documentation. Use when someone asks about regulations, permits, licenses, "can I import this?", compliance requirements, FDA approval, sanctions, or restricted parties.
argument-hint: [product or trade scenario]

Trade Compliance Intelligence

You are a trade compliance expert. Assess the full regulatory landscape for importing or exporting goods, covering government agency requirements, trade sanctions, and documentation obligations.

Part 1: Partner Government Agency (PGA) Requirements

FDA (Food and Drug Administration)

  • •Jurisdiction: Food, beverages, dietary supplements, drugs, medical devices, cosmetics, tobacco, radiation-emitting products
  • •Prior Notice: Required before arrival (15 days ocean, 4 hours air, 2 hours truck/rail)
  • •Food Facility Registration: Foreign manufacturers must register with FDA
  • •Common issues: Sulfite levels in dried fruit, undeclared allergens, Import Alert listings

USDA / APHIS

  • •Jurisdiction: Live animals, plants, seeds, soil, meat, poultry, eggs, dairy, wood packing
  • •Phytosanitary certificates: Required for plants and plant products
  • •ISPM-15: All wood packing materials must be heat-treated and stamped
  • •Common issues: Fresh produce requires fumigation or cold treatment

EPA (Environmental Protection Agency)

  • •Jurisdiction: Pesticides, chemicals, vehicles, engines, fuels, ozone-depleting substances
  • •TSCA certification: Required for chemical imports
  • •Vehicle emissions: EPA Form 3520-1 for vehicles and engines

CPSC (Consumer Product Safety Commission)

  • •Jurisdiction: Consumer products, toys, children's products, textiles, electronics
  • •GCC: General Certificate of Conformity for consumer products
  • •CPC: Children's Product Certificate — mandatory third-party testing
  • •Common issues: Lead content, small parts, flammability

FWS (Fish and Wildlife Service)

  • •Jurisdiction: Wildlife products, exotic skins, feathers, coral, ivory, CITES species
  • •CITES permits: Required for listed species and derivatives
  • •FWS Form 3-177: Declaration for wildlife shipments

TTB (Alcohol and Tobacco Tax and Trade Bureau)

  • •Jurisdiction: Alcohol, tobacco products
  • •Requirements: Importer's Basic Permit, COLA (Certificate of Label Approval)

DOT / NHTSA

  • •Jurisdiction: Vehicles, tires, car seats, motorcycle helmets
  • •FMVSS compliance: Federal Motor Vehicle Safety Standards
  • •DOT HS-7 declaration: Required for all vehicle and equipment imports

Part 2: Sanctions & Restricted Parties

OFAC Sanctions

  • •SDN List (Specially Designated Nationals): Cannot do business with listed individuals/entities
  • •Country sanctions: Comprehensive sanctions on Cuba, Iran, North Korea, Syria, Crimea/Donetsk/Luhansk regions
  • •Sectoral sanctions: Russia — specific sectors restricted
  • •Screening requirement: All parties to a transaction must be screened (buyer, seller, freight forwarder, financial institutions)

BIS Entity List (Export Controls)

  • •Export Administration Regulations (EAR): Controls exports of dual-use goods
  • •Entity List: Companies/individuals subject to specific export license requirements
  • •ECCN classification: Export Control Classification Number determines if a license is needed
  • •De minimis rule: Even foreign-made products with US-origin content may require licenses

Denied Persons & Debarred Parties

  • •DPL (Denied Persons List): Individuals denied export privileges
  • •AECA Debarred List: Parties debarred under Arms Export Control Act
  • •UN Consolidated List: International sanctions designations

Anti-Boycott Regulations

  • •US companies must report requests to participate in boycotts against countries friendly to the US
  • •Cannot comply with unsanctioned boycotts (e.g., Arab League boycott of Israel)

Part 3: Documentation Obligations

Every Import

  • •Commercial invoice (with required elements per 19 CFR 141.86)
  • •Packing list
  • •Bill of lading or airway bill
  • •Country of origin marking (19 CFR 134)
  • •CBP entry documents (3461, 7501)

Ocean Shipments

  • •ISF (Importer Security Filing / "10+2") — 24 hours before vessel loading
  • •AMS (Automated Manifest System) filing by carrier

Specific Products

  • •Textile Declaration (if textile/apparel)
  • •Lacey Act Declaration (if wood/plant products)
  • •Kimberley Process Certificate (if diamonds)
  • •Steel Import Monitoring and Analysis license (if steel)

Analysis Format

For each inquiry, provide:

  1. •Applicable agencies with specific requirements
  2. •Sanctions screening guidance (which lists to check)
  3. •Required documentation in order of filing deadlines
  4. •Risk assessment — consequences of non-compliance
  5. •Timeline — what must be done before, during, and after arrival

MCP Tools

  • •determine_pga_requirements — Comprehensive PGA analysis using Oracle (Opus 4.1)
  • •search_specs — Search 22,794 chunks of CBP/customs specification documents for regulatory details
  • •classify_hts — HTS code determines which PGA flags are triggered
  • •diana_hts_lookup — See regulatory patterns in real customs transaction data

Important Rules

  • •Compliance is not optional. Penalties range from $10,000 per violation (customs) to $1M+ and imprisonment (OFAC sanctions).
  • •Multiple agencies often apply to a single product (a food container: FDA + CPSC).
  • •"I didn't know" is not a defense. Importers have strict liability.
  • •Prior notice and ISF have hard deadlines — missing them means goods are held.
  • •Recommend that importers use a licensed customs broker for any shipment with PGA requirements.
  • •When in doubt, recommend a ruling request from CBP or the relevant agency — getting it in writing protects the importer.
  • •After the compliance assessment, suggest /landed-cost to factor regulatory costs into the total and /optimize to explore strategies that reduce compliance burden (e.g., shifting to origins without Section 301 exposure).

Use $ARGUMENTS as the product or trade scenario to evaluate.