LinkedIn Comment

David J. DiSanto• DiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization4h • 

Good luck with increasing your private fleet….DG

The driver shortage, aggravated by the coronavirus pandemic, is reverberating throughout the trucking industry. The problem has reached the point where fleets are noting a shallower pool of independent drivers.
“The available pool of independent contractor drivers is smaller than it has been historically,” Truckload carrier Marten Transport stated in its annual report, filed March 1 with the Securities and Exchange Commission.

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

I agree with you Dave. I’m sure DG has done their due diligence. However, a private fleet is a risky move and just as likely to add costs rather than reduce them. A couple of big questions: Will drivers be company employees with full benefits? Will the fleet have access to back hauls or will there be significant deadheading?

Screen Yourself

I frequently conduct no fee discussions (phone or Zoom) with new clients to determine if I can help them. They may be unsure about their HTS codes or a specific regulation. Exporters quite often assure me that their commodities fall under EAR 99 and NLR (No License Required). While this may be true, due diligence requires verification which starts with checking ECCN (Export Control Classification Number). BIS (Bureau of Industry and Security) spells out the specific procedures for checking ECCN and licensing requirements. The CCL (Commerce Control List) Index is a good place to start.

Here is some more info from the BIS website:

What does EAR99 mean?

If your item falls under U.S. Department of Commerce jurisdiction and is not listed on the CCL, it is designated as EAR99. EAR99 items generally consist of low-technology consumer goods and do not require a license in most situations. However, if your proposed export of an EAR99 item is to an embargoed country, to an end-user of concern, or in support of a prohibited end-use, you may be required to obtain a license.

Contact mitch@ for assistance

LinkedIn Comments


Post from Ira Kawaller

The transition to a new administration offers the opportunity to review federal priorities with respect to international trade policies. Reconsideration of our use of tariffs should be at the top of the list.

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

Well said. This post clearly and concisely states the view that tariffs burden US consumers and businesses more than other parties. Using tariffs to punish or retaliate is poor trade policy.

Country Commercial Guides

How About Those Regulations ?

My last post was about AEC/EEI filing for US exports, which has become routine for most shippers. The real complexity in international trade is the many different regulations applying to destination countries.

Customs delays in other countries are problematic, requiring a lot of time and effort to resolve. Best practices in exporting include due diligence and research when shipping to a country for the first time. The Country Commercial Guides published by the International Trade Administration are an excellent no cost starting point. Here is the link:

LinkedIn Comments

Michael DeMarco• Licensed Freight Broker and 3PL specializing in FTL | LTL | First and Final Mile | Drayage | Project Cargo. With old fashioned customer service we help shippers and logistics companies keep their supply chains moving.

Freight Class. If you are a shipper it would be very wise to know and understand this process. This is the single most important factor when determining LTL rates. It is also the single largest issue when a shipper is hit for overages on a shipment. Incorrect freight classes will get you into a lot of trouble. 

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

Good advice, Mike. Just like with HTS codes don’t assume – verify.

LinkedIn Comments

U.S. Department of Commerce

Small, medium, and large businesses all have the amazing opportunity to expand internationally, however, there are several steps that must be taken to ensure that your company is ready to export. the International Trade Administration shares information on getting started here:

Mitch Kostoulakos, LCB Licensed Customs Broker, International Logistics Consultant

Excellent resources for businesses

Alphabet Soup


By now most exporters are quite familiar with electronic export information filing. The old yellow paper SEDs are long gone. Some shippers self file but many rely on their freight forwarders. In either case it is a best practice to audit your submissions on a regular basis to ensure accuracy and avoid fines and penalties.

A common misconception is that EEI and Commercial Invoice value should match. This is actually not correct unless inland freight costs are added to both. Here is the relevant language from 15CFR Part 30.6

(17) Value. In general, the value to be reported in the EEI shall be the value of the goods at the U.S. port of export in U.S. dollars. The value shall be the selling price (or the cost, if the goods are not sold), plus inland or domestic freight, insurance, and other charges to the U.S. seaport, airport, or land border port of export. Cost of goods is the sum of expenses incurred in the USPPI’s acquisition or production of the goods. Report the value to the nearest dollar, omit cents. Fractions of a dollar less than 50 cents should be ignored, and fractions of 50 cents or more should be rounded up to the next dollar.

Ad Hoc Logistics can audit your filings, checking all elements of the EEI for errors. A confidential report will be provided for internal follow up. Contact mitch@ for immediate assistance.

LinkedIn Comments

Pandemic Driven Change in the Workplace: More to Come – Newegg Logistics

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

The new sales model cuts back on “customer entertainment” as a sales tool. Lunches, dinners, sporting events have always been used to retain market share especially in the LTL sector. I have written that clients should not allow their carriers to “reward” them for their business. Remote sales calls can be focused on adding value, problem solving, and pricing when appropriate. Although I’m sure plenty of golf is being played!

Customs Value

I participated in a webinar last week in which one of the topics was invoice value for customs. Following is an overview of the topic.

Customs entries on imported merchandise involve calculating duties and taxes based on commodity classification (HTS), country of origin, and transaction value. In a previous post we discussed the importance of making sure that correct HTS codes are used. In most cases the commercial invoice or CI value is used for duty calculation. In situations where the transaction is not so clear Customs has established an “appraisement hierarchy” to determine entry value. The details can be found in US Customs and Border Protection regulations 19 CFR part 152.  Here is a summary:

Appraisement Hierarchy

1) Transaction Value- actual invoice value

2) Transaction Value of identical merchandise- same country, same class and kind

3) Transaction Value of similar merchandise- same country, commercially interchangeable

4) Deductive Value – start with US retail selling price and deduct commissions, transportation, insurance, duty/tax, and value of further processing

5) Computed Value- sum of the following. Importer can request computed instead of deductive. Includes cost of materials, cost of labor, cost of packaging, profit, overhead, G&A

6) Value if other values cannot be determined- if the value of imported merchandise cannot be determined it will be appraised on the basis of a value derived from the methods set forth in parts 152.103 thru 152.106.

Parts 152.107 and 152.108 detail value if other values cannot be determined or used and unacceptable bases of appraisement.

Contact mitch@ for assistance