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

Experience adds value…

Gustavo Dobles

President at Dobles Productions, Inc. | Business Consulting and Projects | Music Projects

Experience is a journey through time.  

They say it takes 10,000 repetitions for someone to master something. This takes time. If you work in business for 35 years as I have, it translates, at regular 8-hour days, to over 60,000 hours of experience (and this is before adding all the overtime). A wealth of experience. And for me, and I am sure for most, a source of pride. 

So you go through this long journey and then one day you lose your job. All of a sudden, you are counseled that everything you’ve done you are to disguise, take all dates out of your resume, don’t say anything to date yourself, etc.

So i ask: who are we going to fool on the first interview? If we are to be “found out”…”Wow Mary! he’s old”…why go through the socially degrading pretense of disguising who we are? 

Of course, we should not be naive about these things, we can’t control what other people do and it is natural that eventually the young displace the old, but I do ask: “does it have to be this way? Isn’t there a better way? Can we preserve the respect and dignity of people that have worked for many years, built a wealth of experience, with many accomplishments they are proud of?  

Does it occur to the gatekeepers of today that the very system they are perpetuating will grind them next?  

Recruiters, HR executives, CEO’s, people in charge: this practice is not necessary. It may not be done with bad intentions but still it is insensitive. If you have need for our experience, use it, if not, don’t. But either way, do it with human respect and dignity. 

I am 63 years old in a continued journey of experience, and proud of it. If you want to use my experience…well…my age is an inseparable partner. 

If this resonates please share. 

#experience
#humanexperience

Consultants often receive “Just a quick question?” queries from clients or others and everyone responds differently. Most likely the questioner believes that their question is an easy one and is looking for pro bono service. In fact, while it is easy to ask a quick question, an accurate response is not always quick. I will outline how I handle quick questions but first a couple of anecdotes.

One potential client told me up front that they “did not expect to pay for their easy HTS classification”. I advised that I am a professional Licensed Customs Broker and am paid for my time and expertise. I then quoted a reasonable charge for HTS research, CROSS examination, reviewing GRIs and notes, and documenting for future reference.

Another potential client offered to compensate me for checking some regulations by buying me lunch. I politely responded that I sometimes conduct business lunches but always with the client as my guest. I then quoted a minimum charge for the research requested.

I never heard back from either potential client. As a solo practitioner I know that I need to remain flexible and avoid rigid procedures while making sure that I am compensated for my time and expertise. Based on trial and error, here is how I handle “quick questions”.

Active clients– It is easier to keep clients than to gain new ones. So if I can answer a question from an active client on the spot I will do so as a goodwill gesture. This usually involves something simple like identifying a resource for them. If time or research is required I will let the client know how I will handle the request and what I will charge. Most clients understand this approach because I have added value for them in the past. If they have frequent quick questions I may suggest my retainer service which allows them to prepay for brief consultations by choosing a set number of hours.

Prospective clients– This is a little trickier because of situations such as the ones I have described, so I am more selective in my responses. I do try to be helpful so that they will remember me when they have a real project. If time and research is required I will propose the retainer option or quote a minimum charge. I will always try to learn about the potential client’s business so that I can determine their real needs and follow up at a later date.

Former colleagues– One of the benefits of being a FedEx alum is having contacts with excellent colleagues all over the world. A number of active clients have been the result of referrals by former colleagues. Any questions they have are on behalf of their clients which can also be my prospective clients. Their referrals are my compensation. If they have a project requiring time and research I may ask them to connect me to the client if possible. I’m always happy to hear from former colleagues so FedExers don’t hesitate to reach out.

Friends and family- This is rare as I try not to mix personal with professional and I don’t want to charge friends or family. I would accommodate a minor request and give them a referral for anything more complex.

This method is not perfect but works well enough for me in my growing practice. I would be interested in hearing how other consultants handle “quick questions”

Contact mitch@52.91.45.227

Here is a very useful and post by Tony Rodriguez

https://www.linkedin.com/posts/adhoclogistics_nvocc-vs-freight-forwarder-whats-the-difference-activity-6842432850256572416-HJxA

https://www.linkedin.com/posts/adhoclogistics_the-veteran-military-spouse-logistics-career-activity-6841725450335645696-3dN4

Compliance professionals know that an effective ECP (Export Compliance Program) must include C- level commitment and involvement, sufficient funding, well defined and documented responsibilities, on-going training, and internal audits. Weak ECPs lack some of these elements and are simply window dressing or paper programs.

In house compliance professionals are often given responsibility without authority. Further, they may be at mid or lower management levels or in the wrong chain of command. With or without a formal ECP, compliance professionals must have the authority to place holds on questionable exports without being overruled by sales, finance, or supply chain. Well written protocols for resolving issues and releasing holds require C-level or legal approval.

All of the above illustrates the importance of compliance independence. This may mean reporting to the CEO, COO, or legal department in order to remove pressure from other groups.

If your in house compliance professional is not truly independent hire a consultant!

Contact mitch@52.91.45.227 for immediate assistance.

The August edition of Logistics Management magazine includes an interesting article by Jeff Berman on the infrastructure legislation working its way through Congress. I have strong political opinions but usually keep them out of my posts and articles. In this case, however, politics and policy have major implications for logistics.

A few years ago I wrote and published a book review of “Wedding of the Waters” which chronicles the building of the Erie Canal. The debate about the project was similar to today’s and centered around the amount of federal funding needed. Of course the canal was completed and transformed commerce in the US as well as globally through the Port of NY/NJ. Later infrastructure projects (which were called internal improvements in the 19th Century) included the transcontinental railroad, the interstate highway system, the St. Lawrence Seaway, and many more. None of these would have been possible without federal funding.

While Public-Private Partnerships and a potential Infrastructure Bank are good politics and good policy, our massive needs also require massive federal funding.

As a former LSP (Logistics Service Provider) account executive, and currently as a Licensed Customs Broker and consultant, I have had many clients assure me that their commodities fall under EAR99 and NLR.

EAR99 means that an item is subject to Export Administration Regulations but is not listed with a specific ECCN (Export Control Classification Number). NLR is the abbreviation for No License Required. The first step in the license/NLR decision is to determine ECCN or EAR99.

The CCL (Commerce Control List) is an index listing commodities and product groups. It is a good starting place for researching ECCNs. Here is the link for your reference:

https://bis.doc.gov/index.php/documents/regulations-docs/13-commerce-control-list-index/file

For help with ECCN contact mitch@52.91.45.227

Bill Connolly, LCB

Mitch, I couldn’t agree more with what you say and honestly, CBP expects brokers to be experts in all chapters while CBP IS Teams focus on certain areas. This is not a knock on CBP by any means. That is why they are such a great resource. Importers, your best bet is a Binding Ruling and I’m amazed at the number of importers who will not file for rulings. Mostly it’s because they do not want to find out the HS they’re using is wrong, but you should want to know your exact costs to protect yourselves and your bottom line.

Mitch Kostoulakos, LCB

Hi Bill thanks for your input. I have also found that importers are sometimes reluctant to request a ruling because they don’t want to “invite “ CBP into their business. I agree that a ruling is good business.

How many classifications per hour should a Licensed Customs Broker be able to complete? This question came up in a recent LinkedIn discussion and resulted in many comments. In my opinion it is not possible to answer the question accurately and even providing a range is problematic. A thorough classification includes HTS lookup, GRI (General Rules of Interpretation) review, checking notes and CROSS (Customs Rulings Online Search System). This is the procedural aspect of classification but there is more. Most commodities require interpretation of the tariff language based on experience. Finally, the process needs to be documented for future reference and parts lists updated.

As an independent consultant and Licensed Customs Broker my most frequent client requests are for classification help. While some commodities are easy to classify, most require research and interpretation. Here is an example of an easy one with no research or interpretation needed:

9506.69.2040 Baseballs

Here is one which is more challenging and time consuming:

8532.10.00 00 Fixed capacitors designed for use in 50/60 Hz circuits and having a reactive power handling capacity of not less than 0.5 kvar (power capacitors).

So what’s your goal; fast or accurate?

For accurate classification help contact mitch@52.91.45.227.