Economic and human rights sanctions have recently been imposed on Russia and Belarus by the US, UK, EU and others. Clients and colleagues in the logistics field know that trade to these nations is restricted so there is not much need for discussion or advice. My knowledge of sanctions is basic, however, so I thought I would do some reading on the topic.
Here is a good starting place:
https://home.treasury.gov/policy-issues/financial-sanctions/faqs
I’m always interested in hearing from those who have taken the CBLE (Customs Broker License Exam). If you took the exam on April 27th you will be anxiously awaiting your results. You also know how difficult the exam is. Many brokers have needed more than one try, so don’t be discouraged if you come up short. If you want to challenge any of the questions here is the link explaining how to appeal.
Contact mitch@52.91.45.227
https://www.cbp.gov/trade/programs-administration/customs-brokers/how-appeal
Interesting post from Daniel Penn Associates
What does baseball have to do with operational excellence?
Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant
As I have noted in my post about baseball and logistics:
We play every day, there are lots of statistics, managers get criticized, and errors can have a big impact.
CBP has posted the Trade and Travel Report for FY21
Astronomical ocean rates, containers in the wrong locations, tight capacity in both trucking and air freight, and shortages of critical components. These are among the issues logistics managers have been dealing with for a couple of years now. It is often noted that supply chain is strategic while logistics is tactical. Day to day logistics consists of planning, execution, and problem solving. Right now it seems that the job is mostly problem solving. This certainly leads to frustration for all parties.
Changing forwarders or other LSPs (Logistics Service Providers) as a solution may be tempting but futile. LSPs are struggling to serve existing clients as best they can. Sales departments are always looking to grow their customer base and, at the same time, maintain existing accounts. Relationships are still the key ingredient and every LSP that I know is working diligently to manage their business.
Freight forwarders are intermediaries and have relationships of their own with ocean and air carriers. The strength of these relationships gives them the bandwidth to provide service to importers and exporters. They work with but don’t control overall capacity and rates.
Many of my posts are about compliance. While responsibility for compliance remains with the USPPI, LSPs can be a valuable resource. Expertise in compliance and documentation is certainly important but first they need to be able to move the freight.
Need help? Contact mitch@52.91.45.227
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. A 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).
For immediate assistance contact mitch@52.91.45.227
Two plus years of supply chain disruptions have required managers to examine and revise their global strategies. This calls to mind the term “wicked problem” from a noted supply chain management text*.
A wicked problem involves multiple stakeholders, each with different interests and values. As a result there is no single common goal , no clear mission, and no universal solution. Any solution, after being implemented, will generate waves of consequences and can result in making the problem worse. A suggested framework for tackling a wicked problem consists of 4 levels of increasing complexity:
Level 1- Process Engineering and inventory management– This is the engineering approach focusing on what is being carried (work, cash, information) and process design within and between organizations. Risk management is about improved visibility and control.
Level 2- Assets and Infrastructure- This is the insurance and financial approach. Nodes and links are examined and strengthened to avoid disruptions along the supply chain.
Level 3- Organizations and Inter-organizational networks– This is strategic level problem solving involving outsourcing, partnering, offshoring, and nearshoring.
Level 4- the Macro Environment- This level uses PEST (Political, Economic, Social, and Technological) analysis of environmental changes. Issues include green and legal/regulatory as well as geo political factors.
We can consider supply chain to be strategic while logistics is more tactical. Global supply chain problems are complex and involve all of the above levels. Logistics problems can usually be managed within Levels 1 and 2.
Contact mitch@52.91.45.227 for immediate logistics support.
*Global Logistics & Supply Chain Management by John Mangan, Chandra Lalwani, Tim Butcher, and Roya Javadpour
If you are taking the CBLE (Customs Broker License Exam) in April you should be well along in your preparations by now. No doubt it will be challenging. Most exams include one or two obscure questions. Here is one that has appeared on past exams.
Importations of switchblade knives is permissible by 15 U.S.C 1244 if:
A. The importation is pursuant to a contract with a branch of the State Militia.
B. The importation is destined for a specific member or employee in a branch of the Armed Forces of the United States specifically for personal pleasure off-duty use.
C. The importation of the switchblade knives have a blade not exceeding 6 inches in length.
D. The entry will contain, among other documents, a declaration in duplicate stating that the switchblade knife has a blade not exceeding 3 inches in length and is possessed by and is being transported on the person of an individual who has only one arm.
E. The entry will contain, among other documents, a declaration in duplicate stating that the switchblade knife has a blade not exceeding 6 inches in length.
Answer – D
There is still time to register for the April 2022 Customs Broker License Exam. The CBP website has details. As noted in a previous post, the exam is challenging, so you will need a study plan for the next 5-6 weeks. Let me know if you would like suggestions about how to prepare. If you are successful in passing the exam the next step is a background investigation and fingerprinting. This process can take up to a year before the license is issued. Best of luck.
Announcement – Customs Broker License Exam Date
The next CBLE will take place on Wednesday, April 27, 2022. Exam registration will open on Monday, February 28, 2022 and close on Monday, March 28, 2022.
contact mitch@52.91.45.227
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.
Contact mitch@adhoclogisics.com