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 mitch@52.91.45.227

Tariff classification requests are often for a “quick code lookup” or a “ballpark duty rate”. For many commodities I may actually be able to provide plausible codes and duty rates with no research, but that would be malpractice on my part . Compliance adds value through attention to detail, established protocols, oversight, and documentation. HTS classification is the first step in both export and import compliance.

Proper classification includes HTS lookup, GRI (General Rules of Interpretation) review, checking both chapter and additional notes, as well as CROSS (Customs Rulings Online Search System). Specs, diagrams, and manuals are helpful. For some commodities it may be necessary to consult with a subject matter expert in engineering, purchasing, or manufacturing for details about the item.

These are the procedural steps of classification, but there is more. Most listings require interpretation of the tariff language based on experience. Finally, the process needs to be documented for future reference and parts lists updated.

For accurate classification help contact mitch@52.91.45.227.

No, I’m not referring to the sci-fi film. As noted in recent posts, HTS and Schedule B codes have been updated for 2023 and both tariffs will post changes throughout the year. Reviewing your codes at least semi-annually is a good business practice. However, in small/medium companies with minimal staffing this can easily be overlooked. When working with new clients checking codes is my first step in helping them achieve compliance with import and export regulations.

Why not take it one step further and develop a parts matrix listing descriptions, HTS codes, Schedule B codes, ECCN, License info, Country of Origin, and any other relevant import/export data? Your matrix will enable you to document new parts additions and changes as they occur. All departments involved in trade will be working with the same information so errors and omissions will be reduced.

Contact mitch@52.91.45.227 for help with your matrix.

The HTS (Harmonized Tariff Schedule) has been updated for 2023 and the changes are significant. The change record lists 22 pages of codes that have been established, discontinued, or modified in the last year. The tariff will be updated throughout 2023 and, for reference, the 2022 version was revised 12 times.

https://hts.usitc.gov/current

Accurate classification is the first step in customs compliance. Best practices include reviewing your HTS codes at least semi-annually.

For help contact mitch@52.91.45.227

Info for Customs Broker Permit User Fee as published in the Federal Register. Payment is due no later than February 24, 2023. The fee is $163.71 for each permit held.

https://www.federalregister.gov/documents/2022/12/16/2022-26940/customs-broker-permit-user-fee-payment-for-2023

Mitch Kostoulakos, LCB• Ad Hoc Logistics LLC, Licensed Customs Broker, International Logistics Consultant9m •

Thanks Matt Springate

US Customs and Border Protection (CBP) issued ruling H290535 on September 29th, 2022, which specifies that CBP interprets suppliers providing HTS Classifications to US Importers of Record as “transacting customs business” and requiring a #customs brokerage license.

Read more about the implications of this ruling and what it could mean for your organization:
https://hubs.ly/Q01qXwBk0…see more

Suppliers Providing HTS Advice IS Transacting Customs Business

Several of my recent posts have focused on the responsibilities of USPPIs (US Principal Parties in Interest) and LSPs (Logistics Service Providers) such as freight forwarders. Export transactions require HTS or Schedule B codes, ECCN or EAR99, NLR or License Exceptions, Country of Origin, EEI filing, and more before the shipment even leaves the US.

The real complexity in international trade is the variety of regulations applying to destination countries. Customs delays in other countries are problematic, requiring a lot of time and effort to resolve. Best practices in exporting include due diligence and research when shipping to a country for the first time.

The Country Commercial Guides published by the International Trade Administration are an excellent no cost starting point. Here is the link:

https://www.trade.gov/ccg-landing-page\

Contact mitch@52.91.45.227 for immediate assistance.

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 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 mitch@52.91.45.227

Most exporters I have worked with use Schedule B codes on their documents and for their EEI filings. Schedule B and HTS codes do not always match, so clients often need to maintain two lists.

If you are maintaining separate parts lists for HTS and Schedule B codes this could be a time saver. Check out the Notice to Exporters on the Harmonized Tariff Schedule (2022 Basic Edition as well as Revisions).

Exporters may use HTS codes in place of Schedule B. Go to https://hts.usitc.gov/ and choose the view tab. As always, there are exceptions, but you may be able to avoid toggling between lists.

Contact mitch@52.91.45.227 for classification help.

As noted in previous posts the HTS (Harmonized Tariff Schedule) has been updated for 2022 and the changes are significant. The change record lists 12 pages of codes that have been established, discontinued. or modified. The tariff will be revised throughout the year. For reference the 2021 version was revised 12 times and the 2020 version 28 times.

It’s time to review your codes.

For help contact mitch@52.91.45.227