You may be looking to add a logistics or compliance pro to your staff and, understandably, want to make a good selection. In the meantime let me suggest training your shippers in some export compliance basics. I have always warned that compliance should not be left to a busy shipping department. However, a few hours of training is a good investment as it will enable shippers to spot possible export violations before shipments leave your dock. It will also allow your new professional to focus on more strategic matters and hit the ground running.

Ad Hoc Logistics has several copyrighted training programs to get you started. Contact mitch@52.91.45.227 for info.

A to Z of Managing Logistics

Exporting for Smart People ( Because You’re No Dummy)

Red Flag Screening for Exports

Jim Dickeson – Trade Compliance Geek• 🌏 Global trade is my passion | Trade compliance is my game | Chocolate is my weakness1d •

Anybody you know? Did you file your last triennial status report? It’s one way to get your name in the Federal Register. I know several on this list, but I believe they’ve all retired.

https://www.federalregister.gov/documents/2022/08/24/2022-18213/notice-of-revocation-of-customs-brokers-licenses

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

Checking the list is a good idea. The license is not easy to obtain so need to protect it. Surprised at the number of revocations.

Many of my clients are hard-working owners or operators of small businesses. They don’t have in-house compliance or logistics expertise, so must wear several hats. Day to day activities or unexpected issues take up most working hours. As a result, functions such as logistics planning and import/export compliance are often unmanaged or left entirely to LSPs (Logistics Service Providers).

Making sure that your business is in compliance with import and export regulations is good risk management as well as good business. Think of it as insurance. A few basic steps can make a big difference and can be implemented quickly.

Ad Hoc Logistics can provide step by step guidelines, train your employees, and set up sustainable procedures. Our copyrighted programs include:

Exporting for Smart People- Because You’re No Dummy

Red Flag Screening

A to Z of Managing Logistics

Contact mitch@adhoclogistics.com for info.

Mitch Kostoulakos, LCB commented on this

Nadeem Virk, LCB• 2ndUsing Trade Compliance to Help You Grow | Licensed Customs Broker (LCB) | Founder and CEO @ VTC5h • 

If you have a couple of year’s worth of trade compliance experience, that LCB designation isn’t going to boost you up that much.

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

Curious post. As an LCB you know how difficult it is to obtain the license. Why de-value the accomplishment?

We are happy to be traveling again after a 2 year hiatus. Just returned from Newfoundland and Labrador with memories of a spectacular landscape, friendly people, and excellent seafood. Unfortunately flight delays are a fact of life today. However, Global Entry enabled us to sail through Customs very quickly upon return to the US. We have used it for several previous trips and recommend it to travelers.

https://www.cbp.gov/travel/trusted-traveler-programs/global-entry

Next up Montreal and Quebec City!

David Noah• President at InterMart, Inc.

Most exporters use freight forwarders to manage international transportation for their goods. But, especially with shipping costs on the rise, you may wonder if you could save money by booking container space on your own. Consider these four points first.

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

There is really no advantage to going it alone with the possible exception of large multi-national corporations. For all other exporters it is best to develop strong freight forwarder relationships.

Nadeem Virk, LCB• 2ndUsing Trade Compliance to Help You Grow | Licensed Customs Broker (LCB) | Founder and CEO @ VTC4h

If you can understand the overall idea of a topic in trade compliance rather than worrying about the details, it will get you very far.

Mitch Kostoulakos, LCB Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant

Attention to detail is a critical factor in compliance.

My recent post “Got Alphabet Soup?” covered ECCNs (Export Control Classification Numbers) and EAR99 which is used for items subject to Export Administration Regulations without having a specific ECCN. License determination is the next step in export compliance and I remind shippers that automatically using EAR99 and NLR (No License Required) is risky.

§ 738.4 DETERMINING WHETHER A
LICENSE IS REQUIRED
(a) Using the CCL and the Country Chart
(1) Overview. Once you have determined that
your item is classified under a specific ECCN,
you must use information contained in the
“License Requirements” section of that ECCN in
combination with the Country Chart to decide
whether a license is required. Note that not all
license requirements set forth under the “License
Requirements” section of an ECCN refer you to
the Commerce Country Chart, but in some cases
this section will contain references to a specific
section in the EAR for license requirements. In
such cases, this section would not apply.

Contact mitch@52.91.45.227 for help with export regulations.

Applicants who passed the April 2022 CBLE (Customs Broker License Exam) are, no doubt, anxiously awaiting issuance of their license. This question from previous exams illustrates part of the process:

Below are the basic requirements to obtain an individual broker’s license EXCEPT:

A. Be a citizen of the United States
B. Not be an employee of the Unites States government
C. Be at least 18 years old at the time of submission of license application
D. Be of good moral character
E. Obtain a passing grade of 75% on the Customs Broker License Exam (CBLE)

The correct answer is C as applicants must be at least 21 years of age. As for D how does CBP judge moral character? An extensive background investigation as noted by CBP:

Each broker license applicant must undergo a background investigation that includes a fingerprint analysis and a review of character references, credit reports, and any arrest record. Arrests or convictions do not necessarily preclude the issuance of a license.

Licensed Customs Brokers are responsible for the assessment and potential collection of revenue for the United States in the form of duties and taxes. They must also ensure that they and their clients comply with the laws and regulations in all transactions. So the background check is more than a mere formality. Be patient applicants!

Clients often say “we’ve used the same harmonized codes for years” and “our products are duty free“. As a Licensed Customs Broker and consultant this tells me that I need to do some checking on the client’s behalf. Using obsolete or invalid HTS (Harmonized Tariff Schedule) codes is a sign of an amateurish operation. It is likely that, for these clients, commercial invoice descriptions need updating. If they are also an exporter we should check ECCNs, License Exceptions, and Schedule B numbers as well.

The tariff archives show that the 2021 HTS was revised 12 times. The 2022 version already lists 6 revisions. Here are the links to the changes: https://hts.usitc.gov/view/list

Don’t assume that your codes are valid. A little due diligence helps avoid problems down the road. Contact mitch@52.91.45.227 for a review of your HTS codes.