Case Study
Securing Duty Savings and Compliance Through a First Sale for Export (FSFE) Program
A global consumer goods company importing through multi-tier supply chains in Asia faced rising U.S. customs tariffs.
Although the company recognized the potential of the First Sale for Export (FSFE) scheme, it lacked the expertise and structure to implement it. DOJÖ was engaged to design and deploy a compliant FSFE program that would unlock duty savings and ensure long-term compliance.
This project was conducted by the DOJÖ team under the direction of Thibaut Grandjean-Vernet.
The Story
With operations spanning multiple regions and thousands of suppliers, the company’s sourcing model involved numerous intermediaries between manufacturers and U.S. import entities. While this structure optimized commercial flexibility, it created challenges for customs valuation.
Internal teams, and in particular the Group VP Tax, had long recognized FSFE as a potential opportunity, but fragmented documentation, supplier variability, and the absence of standardized processes prevented them from moving forward. Without a disciplined framework, attempting FSFE posed serious risks: U.S. Customs Authorities (CBP) could challenge the declarations and customs valuation, resulting in duty reclaims, penalties, and reputational exposure.
At the same time, the financial upside was compelling - FSFE could generate multimillion-dollar duty savings annually if implemented correctly, and the effects of the new U.S. trade policy and significant tariff hikes were set to heavily affect the company. Leadership decided to act, turning to DOJÖ for an expert-led solution that could deliver both compliance confidence and sustainable financial benefit.
The Approach
To successfully carry out this project, DOJÖ’s approach combined regulatory rigor with operational execution, delivered through 2 focused phases:
1. Feasibility Assessment
DOJÖ assessed whether FSFE requirements were met across the company’s sourcing model. This included verifying bona fide multi-tier sales, confirming that goods were clearly destined for the U.S. at the time of the first sale, and evaluating arm’s-length pricing in related-party transactions. This phase also included a transactional document review to ensure compliance with operational FSFE requirements. Each shipment’s paper trail was mapped across contracts, purchase orders, invoices, packing lists, and bills of lading.
The assessment confirmed feasibility while identifying documentation gaps requiring remediation including IT adjustments were needed to secure a strong documentation trail evidencing U.S. destination. A corrective action plan was developed to address weaknesses and standardize documentation flows across multiple sourcing regions.
The deliverable was a concise and actionable Feasibility Assessment Report summarizing findings, savings estimates, and actions to align with FSFE obligations (fit-gap analysis). This phase was accomplished in just 4 weeks.
2. Program Implementation
During this phase, our team supported the client in carrying out the remediation actions identified in the first phase. IT changes were made in particular to ensure that the documentation trail could be demonstrated in the event of an audit. Supplier enablement sessions were conducted to align vendors with the new requirements. A compliance monitoring mechanism was also put in place to ensure continuous audit readiness and to reinforce the company’s sustainability and governance commitments. DOJÖ also designed a standardized FSFE compliance framework, embedding clear SOPs, document checklists, approval workflows, and digital archiving protocols.
Clear ownership was also assigned for each activity linked to program management, ensuring continuity of operations and full regulatory compliance. DOJÖ was further mandated to conduct quarterly compliance audits to confirm correct deployment of the program. This phase was finalized within two months.
The Results
The FSFE program delivered measurable financial and operational impact. By basing dutiable value on manufacturer prices rather than resale prices, the company achieved multimillion-dollar annual savings.
Just as importantly, compliance confidence was strengthened. A fully documented and standardized package ensured readiness for U.S. Customs audits and minimized the risk of penalties or disputes.
The program also secured sustained compliance. FSFE requirements were embedded into daily operations, supported by supplier training, disciplined record-keeping, and quarterly audits conducted by DOJÖ.
Finally, leadership gained a consolidated view of FSFE performance, integrating the savings into broader financial planning and embedding the program within the company’s long-term objectives.
The Takeaway
By partnering with DOJÖ, the company transformed FSFE from a high-risk concept into a strategic compliance and savings engine. The program not only reduced costs but also reinforced the organization’s commitment to principled, efficient operations. What began as a fragmented challenge became a structured, scalable process that continues to generate value in line with the company’s long-term vision.
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