Clients often know that they need help with export compliance but don’t know where to start. This info, from a previous post, should help. A well written and maintained EMCP is the ideal way to keep compliant. However, an EMCP is costly and time consuming. Because there is considerable risk in being non-compliant, don’t make the mistake of doing nothing because you are not in a position to implement an EMCP. You can, and should, take some basic steps.
Implementing a formal Export Management Compliance Program can be quite intimidating 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 exemption 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 firstname.lastname@example.org help.
In previous posts we have discussed the World Bank Logistics Performance Index for international trade. The Index also contains a domestic component as detailed below:
The Domestic LPI looks in detail at the logistics environments in 116 countries. For this measure, surveyed logistics professionals assess the logistics environments in their own countries. This domestic evaluation contains more detailed information on countries’ logistics environments, core logistics processes and institutions, and performance time and cost. This approach looks at the logistics constraints within countries, not just at the gateways, such as ports or borders. It uses four major determinants of overall logistics performance to measure performance:
• Border procedures and time, and
• Supply chain reliability.
Here is some of the data for the US from the 2014 report. The low % of physical inspections stands out.
|Shipments meeting quality criteria (%)
|Number of agencies – exports
|Number of agencies – imports
|Number of documents – exports
|Number of documents – imports
|Clearance time without physical inspection (days)
|Clearance time with physical inspection (days)
|Physical inspection (%)
|Multiple inspection (%)
I have held the CTL certification since 1998. This credential (Certified Transportation and Logistics) is attained by passing a series of exams and completing a research project. The program is rigorous and the certification is well earned. As many AST&L members will attest, the CTL is relatively unknown even within the field of transportation and logistics. I have been asked on occasion if pursuing the CTL is worthwhile and always reply that the effort is a rewarding personal achievement but I cannot honestly say that the CTL has been a big advantage professionally.
Now that AST&L and APICS have announced a proposed merger, I have questions about the CTL long term. The announcement on AST&L’s website includes a statement in the FAQ’s that there will be no changes to designations “in the short term”. I intend to vote in favor of the merger because of the advantages APICS offers in terms of highly recognized certifications and active chapters. I am a member of AST&L’s Education Committee and recently completed the first ever CTL re-certification program. With this significant investment in the CTL, I would like to see stronger affirmation from APICS that the CTL will be maintained and promoted.
Outsourcing logistics functions can be an effective strategy. In many cases, however, there is little oversight of the 3PL during the life of the contract. Outsourcing must start with defining specific scope of work including special services. Most critical is regular (monthly or at least quarterly) performance reviews of the 3PL by management, not just when problems develop.less