After a notice-and-comment period, CBP published Headquarters ruling (HQ) H022168 (Nov. 23, 2009) in which CBP determined that certain payments made to a purported buying agent constituted bona fide buying commissions and, thus, were not included in transaction value as part of the price actually paid or payable or as an addition thereto. Substantially identical merchandise entered on or after February 8, 2010 will be subject to the analysis set forth in HQ H022168.