Most managers or owners of small/medium companies wear many hats and usually do not have in-house logistics or compliance expertise. As a result, major projects such as implementing an Export Compliance Program go on the back burner. But doing nothing about compliance is not an option!
Let me suggest 3 spring cleaning best practices that will help you get started :
1) Scrub your parts list to make sure HTS or Schedule B codes are valid. The tariffs change periodically and we have found that every client parts list reviewed has included obsolete or invalid codes. Once identified these codes can be updated and lists maintained.
2) Check the CCL (Commerce Control List) to see if your commodities are listed. Exports must show the correct ECCN (Export Control Classification Number) in order to determine if a license is required. If you are automatically using EAR99 and NLR you are at risk of violation.
3) Set up procedures for checking common “Red Flags” such as denied parties lists, entities lists, and unverified lists. BIS (Bureau of Industry and Security) has up to date info on their website.
Ad Hoc Logistics can help you manage these tasks.