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Monthly Archives: December 2014
This cohort was very diverse. In the beginning, they weren’t so sure about giving up their Friday nights and Saturdays. But as we proceeded, we heard time and again from these students how they wished they’d taken the course years ago!
I recently completed recertification of my CTL (Certified Transportation and Logistics) through AST&L (American Society of Transportation and Logistics). I believe that professional certifications are a valuable credential. Professionals prefer to do business with other professionals.What is EAR 99?
When the ECCN (Export Control Classification Number) comes up on export documents most shippers automatically enter EAR 99. For license questions NLR (No License Required) is often used as a default exception. While these may be the correct entries, it is a good business practice to check and confirm. Here is some info from a previous post.
As part of any Export Management Program, exporters need to make sure they are using correct commodity classifications and license exceptions. While freight forwarders can provide expertise in these areas the exporter bears primary responsibility for compliance. If you are automatically using NLR and EAR 99 you may be at risk. According to EAR part 732 “For items subject to EAR but not listed in CCL the proper classification is EAR 99. EAR 99 is a basket for items not specified under CCL and appears at the end of each Category on the CCL.”
If you need help contact mitch@52.91.45.227
Incoterms Project
Ad Hoc Logistics is currently helping a client resolve a conflict between Incoterms and Liner terms. In this transaction the Incoterm used is incompatible with the Liner term resulting in a dispute over payment of some fees. Following is some basic info from a previous post about Incoterms.
For help with Incoterms contact mitch@52.91.45.227
Incoterms Basics
Incoterms are rules used to facilitate global trade. Incoterms were created and are administered by the International Chamber of Commerce and are updated every 10 years. Incoterms 2010 published by ICC Services Publications, Paris FR is a very good reference. Some of the important points covered in the book are:
- Incoterms must be in the contract of sale to apply
- > 120 countries have endorsed Incoterms 2010
- Now 11 rules in 2 groups
- 2 new rules deal with geographic place
- Incoterms is not a law…older versions can be used as long as all parties agree
- Incoterms replaces Uniform Commercial Code (UCC) in domestic commerce
- for reference www.iccbooksusa.com
- Incoterms cover;
- Who does what
- Who pays for what
- When risk of goods passes from seller to buyer
- Who is responsible for insurance, export clearance, import clearance, and other costs pertaining to delivery of goods
- Incoterms do not cover;
- Ownership or title to goods
- Payment terms
- Detailed requirements
- Complete contract of sale
Incoterms 2010 includes several rules changes:
- Now referred to as rules not terms
- Remove DAF DES DDU DEQ
- New Rules DAT DAP
- 2 Groups…Any Mode and Ocean/Inland Waterway Only
- Any Mode…EXW FCA CPT CIP DAT DAP DDP
- Ocean or Inland Waterway Only…FAS FOB CFR CIF
Attached chart is a quick guide to Incoterms 2010
Exporting Best Practices for 2015
Do you want to get a handle on export compliance in 2015? Implementing a formal Export Management Compliance Program can be quite intimidating and expensive, especially for small and medium sized companies. An EMCP requires a significant commitment of time on the part of management and usually involves hiring an outside consultant for the initial set up. There is no question that a written EMCP is a good investment for any company to make. An EMCP establishes clear accountability, written instructions, and reduces risk of non compliance. If the exporter has not experienced problems or incurred any fines it is easy to make an EMCP a “back burner” issue. If your company has not implemented an EMCP it is still good business practice to take some basic compliance steps. While these steps cannot take the place of a written EMCP they will help reduce risk of non compliance. To get started I suggest the following:
- Review and confirm correct Harmonized and Schedule B codes
- Check EAR regulations for correct exception codes and license or NLR designations
- If exporting under ITAR you need a responsible trained officer
- Check common “Red Flags” such as denied parties lists, entities lists, and unverified lists
- Review export documentation for possible improvements
Contact mitch@52.91.45.227 for help.