Incoterms 2020

Just received my copy of Incoterms 2020 published by the International Chamber of Commerce. The book is well structured and clearly written. Incoterms are updated every 10 years so there are significant changes in each version.

Incoterms 2020 presents the rules and explanatory notes in simple language along with useful illustrations. The introduction informs the reader about what Incoterms rules do and do not do. For example, Incoterms rules describe obligations, risk, and costs between buyers and sellers. Incoterms do not deal with title or ownership of the goods, which is a common misperception.

Some of the changes made to Incoterms 2010 rules in the Incoterms 2020 rules include:

  • Bills of Lading with an on-board notation and the FCA rule
  • Costs, where they are listed
  • Different levels of insurance coverage in CIF and CIP
  • Arranging for carriage with seller’s or buyer’s own means of transport in FCA, DAP, DPU, and DDP
  • Change in the three-letter initials for DAT to DPU
  • Inclusion of security-related requirements within carriage obligations and costs
  • Explanatory notes for users

This post is not a book review but an introduction to a valuable resource for anyone involved in trade. I plan to study Incoterms 2020 and incorporate some formal training in the next few months so that I can provide guidance to clients.

contact mitch@

Are You a Deemed Exporter?

Posted on LinkedIn

Are you a Deemed Exporter?

Engineering firms, software companies, researchers, manufacturers, and universities need to be aware of the “deemed export” rules. They may be engaged in export transactions without even knowing it.

Check out the Bureau of Industry and Security’s newest online training video, “Deemed Exports,” now available on the BIS Online Training Room at

Customs Broker Exam

Best of luck to applicants taking the Customs Broker Exam on October 17th. For anyone thinking about applying for a future exam here is a question from the April 2019 exam. I will post the answer next week and also respond to anyone who submits their answers.

10. Die cut steel plier levers were bolted together in China before having rubberized non-slip grips attached to each lever handle in Germany prior to being imported into the United States. What is the proper country of origin and marking method?

A. Made in Beijing printed on a hangtag

B. Made in China printed on a sticker attached to the pliers

C. Made in China die stamped into the pliers

D. Assembled in Germany printed on a sticker attached to the pliers

E. The pliers are exempt from marking in accordance with the J list

Trading Across Borders

In previous posts we have reported on the World Bank Logistics Performance Index and how the United States ranks compared to other nations.

Another view of world trade is presented by the World Bank in their report Trading Across Borders- Doing Business. In the most recent report the US ranked 36th in trading across borders. Here is a link to the report along with some introductory info.

 Trading across Borders

Doing Business records the time and cost associated with the logistical process of exporting and importing goods. Doing Business measures the time and cost (excluding tariffs) associated with three sets of proceduresdocumentary compliance, border compliance and domestic transportwithin the overall process of exporting or importing a shipment of goods. The most recent round of data collection for the project was completed in May 2018. See the methodology for more information

Red Flags (Continued)

From the archives….

In a previous post I discussed Red Flags to be aware of in export transactions. Here is more detail from the Bureau of Industry and Security about the Consolidated Screening List. The Department of Commerce lists that are included in the Consolidated Screening List are: Denied Persons List, Unverified List, and Entity List. For help with export compliance contact mitch@

Consolidated Screening List

Prior to taking any further actions, users are to consult the requirements of the specific list on which the company, entity or person is identified by reviewing the webpage of the agency responsible for such list. The links below will connect you to the specific webpage where additional information about how to use each specific list is contained.

Department of Commerce – Bureau of Industry and Security

  • Denied Persons List– Individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial order are prohibited.
  • Unverified List – End-users who BIS has been unable to verify in prior transactions. The presence of a party on this list in a transaction is a “Red Flag” that should be resolved before proceeding with the transaction.
  • Entity List – Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The list specifies the license requirements and policy that apply to each listed party.