Many of our posts focus on the basics of export compliance. Due diligence is required when filing EEIs, classification of Schedule B and ECCNs, and Country of Origin determination. An Export Compliance Program (ECP) is highly recommended as well as red flag screening, training, and audits. In spite of best efforts, mistakes will be made. In these cases a Voluntary Self-Disclosure is a smart move. Here is some info from the BIS (Bureau of Industry and Security) website:
Parties who believe they may have committed a violation of the EAR are encouraged to submit a Voluntary Self-Disclosure (VSD) to BIS. VSDs are an important indicator of a party’s desire to bring their export activities into compliance, and also may provide important information to BIS helping to identify foreign proliferation networks. Parties submitting VSDs may be eligible for significant reductions in administrative penalties, and those with well-implemented EMCPs may expect further significant reductions of administrative penalties. Procedures for submitting VSDs may be found in Section 764.5 of the EAR. The procedures detailed in Section 764.5 do not apply to VSDs involving violations of the antiboycott provisions of the EAR. Procedures for submitting VSDs for boycott violations are found in Section 764.8 of the EAR.
Is Logistics still a people business or is the digital marketplace technology replacing the need for skilled 3PL/Logistics Pros? Or will tribal knowledge still remain a powerful differentiator?
In my opinion logistics providers must offer both high level technology and skilled people. Problem solving is a big part of logistics and clients want to follow up with trusted human contacts.
The June edition of Logistics Management magazine includes a very informative article by John Schulz. Cross-Border Update illustrates the growth and complexities of trade among the three North American nations.
Along with information about USMCA and CTPAT, the author advises that in-house logistics teams must be properly trained on how to develop and maintain a classification matrix for commodities that are shipped across borders. This matrix should include Harmonized Tariff Schedule number, Schedule B number, Export Control Classification Number (ECCN), Export License Authorization, and Country of Origin, as well as any other pertinent customs data.
It is disappointing to see that the USPS has invested 6 years in a new vehicle search process with a flawed result, that does not embrace electric vehicles (EV’s) Clearly, it was not a major objective for the USPS to specify a major, future role for EV’s during the evaluative process. Most likely, the organization must have intentionally specified a limited role for EV’s during the process with potential suppliers.
As the infrastructure debate continues, here is some interesting info from ASCE (American Society of Civil Engineers). Take a look at your state’s infrastructure report card.
I thought about this recent post after meeting with a well established freight forwarder this week. They are focused right now on finding capacity for imports from Asia in order to serve their clients. The current supply chain disruptions illustrate the importance of freight forwarder relationships. Expertise in compliance and documentation is certainly important but first they need to be able to move the freight.
NLR (No License Required) is not always appropriate for export transactions. Here is a useful guide to license exceptions:
A “license exception” is an authorization described in part 740 of the EAR that allows you to export, reexport or transfer in‐country under stated conditions, items subject to the EAR that would otherwise require a license.
In a recent post we discussed 3 common causes of customs delays: vague or incomplete descriptions, questionable valuations, and lack of IOR contact info on commercial invoices.
Those are the easy fixes. More difficult and frustrating customs issues involve country specific regulations that are not known prior to the transaction.
One of our more proactive clients asked Ad Hoc Logistics to research and develop a set of regulatory guidelines for 10 countries to which they export. This has helped prevent costly customs delays and time consuming follow up.
Why not be proactive when shipping to a new country? We can provide all the info you need.
The article cites driver shortage as a big factor in tight capacity and vaccinations may make more drivers available. Would be interesting to learn how much of this profit is being passed along to employees.
