Forced Labor is an important issue for importers and customs brokers to understand and it is complex. I decided to educate myself on the topic and found a good overview and set of resources on the CBP website. Here is the link:
Monthly Archives: March 2023
How’s Your Boilerplate ?
In the 19th Century boilerplate meant rolled steel templates used to make boilers and the printed material on the plates.
Today, the term boilerplate refers to standardized text, copy, documents, methods, or procedures that may be used over again without making major changes to the original. Boilerplate is commonly used for efficiency and to increase standardization in the structure and language of written or digital documents.
Traders when was the last time you reviewed your Commercial Invoice for accuracy or updates? Chances are it has been quite a while, given the more immediate challenges in logistics today. The same question applies to documents produced by your freight forwarder. Checking your CIs for accuracy is a best practice and can help reduce customs delays. Reviewers with “fresh eyes” are an even better idea.
While there is no universal standard format for commercial invoices, including the following key elements will help reduce customs delays and entry mistakes:
Description of goods – Vague or incomplete descriptions are the most common cause of customs delays. Avoid trade names, brand names, jargon. What is it? What is it made of? What is it used for?
Recipient or Importer of Record contact info- customs delays are often prolonged by slow communication between CBP and importers or between exporters and customs agencies in other countries. Make sure phone and e mail info is spelled out on the CI.
Invoice Number, Page Numbers – Avoids confusion for entries with multiple CIs or CIs with multiple pages.
Country of Origin– Best to use ISO country codes.
Related/Not Related parties
Incoterms and currency- these are elements of the sales contract. Indicate version of Incoterms (2010, 2020) as all parties may not be aware of updates.
Harmonized tariff code to the 6 digit level– if unsure best not to include this info.
Summary of Value- must include IV Invoice Value. Can also include NDC Non Dutiable Charge (subtractions), AMMV Add to Make Market Value (additions), NEV Net Entered Value (bottom line- dutiable).
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I am pleased to accept appointment to the Merrimack Valley Regional Transit Authority (MVRTA) advisory board as Selectmen’s designee for the Town of Merrimac.
Most managers or owners of small/medium companies wear many hats and usually do not have in-house compliance expertise. As a result, major projects such as implementing an Export Compliance Program go on the back burner. But ignoring 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 and Schedule B codes are valid. The tariffs change periodically and we have found obsolete or invalid codes on 100% of clients’ parts lists. 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.
Logistics and Baseball
I’ve always loved baseball and attribute my math skills to studying the back of favorite players’ cards. The basic statistics were batting average, home runs, and rbi for hitters. For pitchers it was wins-losses and earned run average. These measures don’t even scratch the surface compared to the sabermetrics used in today’s game.
Logistics and baseball have some common features. We play every day, errors can have a big impact , managers get criticized, and there are plenty of rules and regulations. Like sabermetrics in baseball, we can measure logistics performance in many different ways.
Measuring and managing logistics performance is a full time job for professionals and the volume of data can be daunting. Managers in other functions such as finance, marketing, or manufacturing may need a quick view of logistics data as it relates to their responsibilities.
Here are a few general measures for the dashboard:
Absolute Performance- monitor absolute logistics failures rather than percentages. For example, 99.5% on time performance appears very good. However, in a high volume operation, it could mean hundreds or thousands of late orders per day.
Inventory Turnover- common measurement in asset mgt.
Order Fill Rate- customer service and warehouse productivity measurement. Can also use item, line, or value fill rate.
Warehouse Utilization %- indicator of good asset mgt.
Warehouse Productivity- measure of units received, stored, picked, packed, and shipped per hour.
Order Cycle – reduced order cycle means less inventory in the system and greater customer satisfaction. Longer order cycle means more inventory in the system and reduced customer satisfaction.
Lost Sales- inverse relationship with inventory. Higher inventory costs, lower risk of lost sales. Lower inventory costs, higher risk of lost sales.
Transportation costs- always a trade off….bulk shipments can reduce transportation costs but leads to higher inventory levels in system. Higher transportation costs due to mode shift (air vs. ground or air vs. ocean) can reduce inventory in system by shortening the order cycle.
Commodity value- higher dollar value means increased transportation, inventory, and packaging costs.
Density of product- High density (lbs/ cubic ft or kgs/ cubic meter) means lower transportation and inventory costs since the product takes up less space in containers or warehouse.
Loss and Damage- greater susceptibility to loss or damage means higher transportation rates and higher warehousing costs due to special handling.
Location Decision- Distance from sources or markets = relative advantage or disadvantage vs. competitors. This is a C level responsibility.
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Exporters, what has prevented you from implementing an Export Compliance Program? Here are the most common self-imposed roadblocks:
Inertia- initial steps are taken to develop an Export Compliance Program but progress stalls as more urgent tasks need attention.
Management believes that company is too small or doesn‘t export enough to need a formal ECP.
Lack of upper management commitment and/or willingness to put in the time.
Management doesn’t want to spend the money or devote resources to create an ECP.
Compliance is managed at lower levels with limited authority to get the project done.
Reliance on Logistics Service Providers for compliance. While LSPs are valuable business partners, the exporter is ultimately responsible for compliance.
An effective Export Compliance Program includes these elements: Management Commitment, Risk Assessment, Export Authorization (Agency Jurisdiction), Record Keeping, Training, Audits, Handling Export Violations (Corrective Action), and Build and Maintain an ECP Manual.
The most important element, by far, is Management Commitment. C-Level executives must allocate resources, communicate the importance of an ECP throughout the organization, and hold everyone accountable. Without strong management commitment and involvement you will end up with a weak program.
If you would like to get started contact firstname.lastname@example.org