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Greetings!
Thank
you once again for taking time to read our monthly newsletter. We
hope that you find it informative and useful. It remains our goal
to bring you a recap of important trade news covering the last
month.
Our readership continues to grow every month. If you enjoy this
newsletter please consider sharing it with your colleagues. Simply
click on the "Forward to a Friend" icon found below and enter the
e-mail address.
As always, the Trade Innovations Team welcomes your ideas,
questions, or suggestions. We can be reached by e-mail at
info@tradeinnovations.com. In the meantime, please accept
our wishes for a safe and enjoyable summer.
Sincerely,
The Trade Innovations
Team
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Trade News Briefs |
Importer
Security Filing - No Penalties Yet:
Continuing with their escalated
enforcement plan, U.S. Customs & Border Protection (CBP) has
not issued its first liquidated damage claim for failure to file
the Importer Security Filing (ISF). However, shipments arriving on
U.S. shores without an ISF are being detained and CBP is sending
those importers letters. We do not foresee any penalty actions for
the remainder of this calendar year. We anticipate that CBP will
move to the penalty phase sometime in the first quarter of 2011,
possibly as early as late January.
CBP Urged to Provide Benefits
for Highly Compliant ISF Filers: At the August 4th public
meeting of the Commercial Operations Advisory Committee (COAC) CBP
was encouraged to provide meaningful benefits for highly compliant
ISF filers. We'll keep you apprised on the progress of these
recommendations.
CBP Abandons Challenge to
First Sale Valuation Methodology: In July CBP Commissioner Alan Bersin
formally advised the trade community that CBP intends with withdraw
its proposal to adopt a last sale rule. This announcement ends
more than two years of uncertainty since CBP first announced its
intent to stop using the first sale methodology in the Federal
Register on January 24, 2008.
BIS Seeks Comments on Best Practices: The Bureau of Industry and Security
(BIS) is seeking public comment on a set of proposed "Best
Practices for Transit, Transshipment, and Reexport of Items Subject to the Export
Administration Regulations." The comment period closes 45 days
from August 27, 2010. For a copy of this notice please click here:
BIS
Public Inquiry
DHS Issues Progress Report in Implementing 9/11 Commission
Recommendations: Last month the Department of Homeland Security
(DHS) issued an update on their progress in implementing the
recommendations of the 9/11 Commission. For a copy of that report
please click here: DHS
Progress Report July 2010
Most Common Reasons for
Outbound Detentions and Seizures: CBP held a webinar in
June to discuss the most common causes of detention or seizure of
U.S. exports. The number one reason was the absence or untimely
filing of the Electronic Export Information in the Automated Export
System (AES). To download a copy of the PowerPoint CBP used in
this webinar please click here: CBP
Outbound Webinar June 2010
CBP Commissioner gets High Marks: CBP Commissioner Alan
Bersin is getting rave reviews on trade matters from inside and
outside of The Beltway. He has been quite visible in the trade and
has met with industry leaders on numerous occasions.
Colleagues who work with him say he is pragmatic and personable, he
listens and he acts. This broad support for Bersin can be found in
both the government and private sectors.
Bersi n was one of President Obama's now
infamous "recess appointments" made on March 27, 2010 and
unfortunately remains unconfirmed. Unless he is ultimately
confirmed by the Senate, Commissioner Bersin will be
required to step down in December 2011.
When the mid-terms are over we anticipate that the major trade
associations will make a concerted effort to get Commissioner
Bersin confirmed.
DHS Holds Supply Chain
Security Strategy Session: On August 25th DHS convened a
group of subject matter experts (SME's) from the trade to
discuss supply chain security strategy. The
meeting was hosted by Georgia Tech Research Institute and DHS
Assistant Secretary for Policy Development, Arif Alikhan.
Participants discussed a variety of topics including macro trends,
tangible collaboration, risks and opportunities. Trade Innovations
Principal Michael Laden was honored to be one of the sixteen SME's
invited to attend; other attendees included Dr. Stephen Flynn,
Center for National Policy, Dr. Henry Willis, RAND, and Jay Ahern,
former CBP Deputy Commissioner.
CBP
Situatio n Room Renovations: The CBP
Situation Room in the Ronald Reagan Building has undergone a
renovation that includes a new state-of-the-art 5 foot by 15 foot
video wall. This high tech area is manned by the Commissioner and
his staff during a crisis and also acts as a central nerve point
for CBP operations around the globe.
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A Customer
too Far...
By Kelby Woodard
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We are all
in the business of satisfying current customers and cultivating new
ones (or at least should be). When you are engaged in
international trade, however, you have to be careful. Not knowing
who you are doing business with can cost you and your company
dearly in terms of monetary fines and corporate reputation. Case
in point is the recent finding against the insurance giant Geico.
As it turns out the U.S. Department of the Treasury is interested
not only making sure you pay your taxes, they are also interested
in who your customers are. The Office of Foreign Assets Control
(OFAC) within Treasury is responsible for enforcing U.S. trade
sanctions based on national security goals. In other words, they
do not want you doing business with 'bad characters'. In Geico's
case the customer (a.k.a. 'bad character') also happened to be a
known narcotics trafficker which is a direct violation of the King
Pin Act. (more follows, to
read the entire article click the link below)
To read the entire article
click here: A Customer too
Far...
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Free
Information
By Michael Laden
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Did you know that
the U.S. Customs & Border Protection (CBP) web site contains a
veritable wealth of useful information? For example there's an
entire series of informative publications called, "What Every
Member of the Trade Community Should Know About..." The series
covers important topics like, the ABC's of Prior Disclosure,
Recordkeeping, Rules of Origin, Reasonable Care, Tariff
Classification, and many more commodity specific topics. To review
the complete list of Informed Compliance Publications please follow
this link: CBP Informed Compliance
Publications. (more
follows, to read the entire article please click the link
below).
To read the entire article click here: Free Information
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Wisps of
Wisdom
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Incoterms 2010
One of the most common
mistakes we see with clients engaged in foreign commerce is a
misuse or misunderstanding of the Incoterms� in a transaction.
Incoterms rules explain standard terms that are used in contracts
for the sale or purchase of goods. They are essential tools that
help traders avoid misunderstandings by clarifying the costs,
risks, and responsibilities of both buyers and sellers. They are
established and set by the International Chamber of Commerce
(ICC). This month the ICC will release Incoterms 2010, they will
go into effect on January 1,
2011.
Incoterms will be distinctly
separated into two categories:
- Incoterms for any mode or mode
of transport
EXW - Ex Works
FCA - Free Carrier
CPT - Carriage Paid To
CIP - Carriage and Insurance
Paid
DAT - Delivered At Terminal
(new)
DAP - Delivered At Place (new)
DDP - Delivered Duty
Paid
- Incoterms for sea and inland
waterway only
FAS - Free Alongside Ship
FOB - Free On Board
CFR - Cost and Freight
CIF - Cost, Insurance and
Freight
The
reduction in Incoterms from 13 to 11 different terms was
accomplished by substituting two new terms, DAT (Delivered at
Place) and DAP (Delivered at Place) for DAF (Delivered at
Frontier), DES (Delivered Ex-Ship), DEQ (Delivered Ex-Quay) and DDU
(Delivered Duty Unpaid).
Incoterms� 2010 will also address duties to provide information
regarding security-related clearances, such as Importer Security
Filings and other chain-of-custody
information.
Routinely we will engage clients with Procurement or Marketing
staff that do not know the difference between DDU and DDP. Simply
stated if you do not have a good command of the Incoterms and
exactly what they mean it is very likely that you may be incurring
unexpected costs that have a negative impact on your
margins.
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Importer Security Filing (ISF) Made
Easy |
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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 ($5 per ISF, or $3 per ISF if you also file
your customs entry with TRG Direct) 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.
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World
Customs Forum 2010 - Istanbul
Building Momentum for an
Effective Partnership is the theme of this year's World
Customs Forum. This two-day conference focusing on essential
building blocks for public-private collaboration in modernization
of the international supply chain will be held on October 6th and
7th in Istanbul, Turkey at the Renaissance Polat
Hotel. To view a copy of the most current agenda please
follow this link: World Customs Forum
2010.
This event will be graciously hosted by Turkish Customs and the
conference and jointly sponsored by the World Customs Organization
(WCO) and the Trusted Trade Alliance. The agenda will feature
Government and Multilateral Policymakers, Senior International
Logistics Professionals, Trade Compliance and Supply-Chain
Managers, Corporate and Trade Organization Executives, Supply-Chain
IT Providers, Legal Advisors, Academics and Economists.
Space is limited, please mark your calendars and save the date
today for the most important WCO event of the year. For more
information or to register for the event please click here: World Customs Forum 2010
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Click here
to visit the Trusted Trade Alliance LLC (TTA)
site
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