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Greetings!
We hope that this is just what you need; a concise synopsis of important trade news from the preceding month. We also hope that you find this edition informative and useful. As time and schedules permit, we will also publish one or two featured articles each month.
Our readership continues to grow with every issue. If you enjoy this newsletter please consider sharing it with your colleagues. Simply click on the "Forward to a Friend" icon found at the bottom.
As always, the Trade Innovations Team welcomes your ideas, questions, or suggestions. We can be reached by e-mail at info@tradeinnovations.com.
Sincerely,
The Trade Innovations Team
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Trade News Briefs
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CBP Announces COAC Members: U.S. Customs & Border Protection (CBP) recently released the names of the appointees to the 12th term of the Commercial Operations Advisory Committee (COAC); included on the list are two former Customs Commissioners, Carol Hallet and George Weise. COAC is a 20-member blue ribbon panel from the private sector and they advise the Secretaries of Treasury and Homeland Security on matters relating to the commercial operations of CBP. For a list of the names or to read more please follow this link: COAC Appointees.
ACE Delivers Benefits: After years of development and literally billions of dollars in programming, the CBP Automated Commercial Environment (ACE) is finally delivering some benefit to the trade community. The reporting users can extract from the ACE Portal has improved dramatically and CBP seems to be making good progress on other fronts in programming as well. However with that said, ACE still lacks enough functional edits to be considered by most for their daily production activities. For example, ACE will not currently reject a bad or incorrect tariff number; the system will simply accept the errant number and then the Importer of Record may be subject to penalties.
Despite its current shortcomings, we recommend importers consider signing up for the ACE Portal. It's free, it's easy and it contains all of the pertinent data you will need to manage your company's compliance. For more information or to sign-up please follow this link: ACE Portal Information.
Radiation Screening on Japan Cargo: CBP and the Coast Guard have been actively involved in screening all inbound cargo from Japan for traces of radiation. The first maritime container arriving from Japan after the devastating earthquake and subsequent tsunami arrived in Long Beach on 3/22 on board the APL Korea. CBP has formulated a cautious and measured approach to radiation screening and their protocol is flexible and can be adjusted as necessary based on conditions. Basically the plan calls for CBP to meet vessels arriving from Japan dockside to perform an initial screening of the top decks. If no harmful levels of radiation are detected then CBP will pull back to normal operations. CBP Holds Roundtable: Trusted trade and automat ion were two of the hot topics at a trade stakeholder roundtable hosted by CBP on March 15th. Commissioner Alan Bersin (pictured right) and other CBP Executives, including Alan Gina the newly named Assistant Commissioner for Trade. Commissioner Bersin stated that, CBP's overarching trade challenge as transforming "systems geared to a world that no longer exists. We need your help in identifying the changes to be made." To read the full article please follow this link: CBP Roundtable.
CBP C-TPAT Conference: Last week CBP hosted the first C-TPAT conference of the year in San Diego. The second and final conference of the year is scheduled for New Orleans, LA beginning on June 7th. For more information or to register for the June event in New Orleans please follow this link: New Orleans C-TPAT Conference. The San Diego C-TPAT conference was well attended by both the government and private sector. In addition to current Commissioner Alan Bersin, former Commissioner Robert Bonner (in office when C-TPAT was created) also made an appearance. CBP offered participants a number of informative and beneficial workshops and breakout sessions. Commissioner Bersin continues to work with Congress to improve the tangible benefits for C-TPAT importers. With more than 10,000 members, C-TPAT has been hailed as one of the most successful private and public partnerships ever created. Webcast of CBP Trade Symposium Available: The CBP Trade Symposium will be held next week, April 13th and 14th in Washington, DC. The theme for this year's conference is "Working Together to Strengthen Economic Competitiveness". As it was last year, the event will also be available by live Webcast and subsequent on-demand viewing. The Webcast cost is $150. For more information on the CBP Trade Symposium including the agenda and registration for the Webcast please follow this link: CBP Trade Symposium Webcast Registration.
Look for our complete Trade Symposium recap in next month's newsletter.
CBP Publishes Trade Strategy Document: One of the breakout sessions at this years CBP Trade Symposium is called Trade Strategy. In preparation for that discussion CBP released the attached document 2-page document. The CBP strategy contains four key elements:
* Facilitate Legitimate Trade and Ensure Compliance
* Enforce U.S. Trade Laws and Collect Accurate Revenue
* Advance National and Economic Security
* Intensify Modernization of CBP's Trade Processes
Trade Innovations Principal Michael Laden will be attending this session and will report the outcome in our May newsletter. For an Adobe copy of the Trade Strategy document please follow this link: CBP Trade Strategy Document.
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Trusted Accounts Revisited
By Michael Laden
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At a recent roundtable hosted by U.S. Customs & Border Protection (CBP) Commissioner, Alan Bersin, the concept of Trusted Accounts was once again broached. I say once again because it is an idea that has been kicked around before, and in 2005 I authored a white paper on Trusted Accounts. Perhaps it's time to take it down from the shelf and dust it off, especially given the Commissioner's willingness to explore the concept.
So what would a Trusted Account program look like? It would essentially be ISA (Importer Self Assessment) on steroids and those importers who could qualify would be treated to an array of benefits; including the best of all, less government intrusion and red tape. (more follows)
Much more follows, to read the entire article or to download an Adobe copy please follow this link: Trusted Accounts Revisited
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Deputize Your Supply Chain
By Kelby Woodard
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 How in the world can you vouch for the security of all those far-flung suppliers that are crucial to your success? This can be particularly difficult when the need for compliance with U.S. security requirements exceeds the resources at your disposal. The answer lies in a dynamic yet simplistic approach to your global partners. Start with a questionnaire that allows your suppliers to self-assess their own security strengths and weaknesses. These first hand experiences are imperfect, but are also the best foundation for your supply chain security program. (more follows)
Much more follows, to read the entire article or to download an Adobe copy please follow this link: Deputize Your Supply Chain
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Controlling and Reporting Assists
For many importers an assist is one of those little landmines that you can step on while navigating the landscape of international trade. Recognizing if you have them is just one of the problems, controlling them to ensure they are accurately reported is another. Having undeclared assists is one of the most common discrepancies that CBP finds when conducting compliance audits. Failing to properly identify and declare assists can result in penalties or other enforcement actions by CBP. Assists are a definite "hot button" for CBP during an audit or Focused Assessment; especially if you are a manufacturer. In short, an assist occurs when a U.S. importer supplies anything of value that assists the manufacturer in the development or production of goods that are subsequently imported. Anything of value can be blueprints, drawings, diagrams, molds or other engineering work. Assists can also manifest themselves in the form of raw materials ordered and paid for by the U.S. importer. Identifying an assist and getting the word out that the value of such assists must be reported is just half of the battle. An importer who has assists must have an efficient internal control for ensuring that the assist is properly declared when the goods are imported; and therein lies the problem. The assist payment is usually made to a second party well in advance of the goods being imported. This detached payment must then be married up and reconciled with the importation of the goods months later. Such payments may be also difficult to track because they typically run across several departments including engineering or R&D and finance. Best practices for controlling assists include:
- Identification and partnership with anyone in the company who may cause an assist;
- General ledger flags for assist payments;
- The ability to flag an item (product code) or vendor for assists;
- Don't wait for assists to come to you, go looking for them continually reminding those who may cause them that you must be notified;
- Frequent training and superb communication;
- Close supervision of broker(s) to ensure assist is reported
The bottom line is that as previously stated assists can be very tricky and difficult to control. There is however one easy methodology for handling assists and that is, DON'T. When it is feasible, introduce the mold-maker or raw materials suppler directly to the manufacturer. Ask the producer to acquire the necessary goods and roll them into their first-cost. This avoids the assist situation completely and takes the importer of record out of the equation.
For more information on assists and other aspects of U.S. valuation law we recommend that you consult the CBP Valuation Encyclopedia; to download an Adobe copy please follow this link: CBP Valuation Encyclopedia
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Web Based HTS Tool
Trade Innovations and our sister company TRG Direct are pleased to announce and introduce a new web-based tool for classifying goods in the Harmonized Tariff Schedules. TRG Classify delivers a 10-digit HTS number to you quickly and accurately by walking you through a step-by-step identification process. The logic in this sophisticated tool is based on the General Rules of Interpretation. TRG Classify is offering free webinar demos of this state-of-the-art system. For further information please visit the TRG Classify web site following the link below.
Click here to visit the TRG Classify web site
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Be sure to visit TRG Classify at the upcoming ICPA Annual Conference in Phoenix, AZ.
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 Importer Security Filing (ISF) Made Easy | |
Often called "Turbo-Tax" for importers, TRG Direct's best-in-class ISF and direct-filing application is extremely intuitive and very easy to use. Leveraging all of the system functionality you can literally file your ISF's in a matter of seconds. TRG Direct's web based system is very versatile and allows multiple users. No permits or licenses are required and any importer can file their ISF's directly with CBP; and your ISF data can now flow directly to a customs entry.
TRG Direct's pricing can save your company up to 90% off current market rates. TRG Direct accepts both XML feeds and Excel uploads to expedite the filing process even more.
Contact TRG Direct today for a free demonstration of the system.
Click here to visit the TRG Direct web site
Smart, Simple, Direct.
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Compliance or Supply Chain Diagnostic
A one or two day on-site review will yield big results
|  Trade Innovations is a world-class leader in providing those companies engaged in global trade with hard-hitting actionable advice to manage and otherwise control global trade programs. In addition to providing a "qualified second opinion" our thought leadership has been responsible for saving companies millions of dollars. Trade Innovations provides advice on a wide variety of supply chain, customs compliance and export compliance matters; this includes assisting companies achieve C-TPAT or ISA status. To inquire about or schedule your compliance or supply chain diagnostic please e-mail us at Trade Innovations E-Mail Request. Click here to visit our web site: Trade Innovations Web Site
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