Clients often ask me to train new employees on the basics of international trade and customs clearance. This includes the roles of LSPs (Logistics Service Providers). Shippers are usually familiar with Freight Forwarders but may be unclear about Customs Brokers. Here is some info from the CBP website for reference:

Customs brokers are private individuals, partnerships, associations or corporations licensed, regulated and empowered by U.S. Customs and Border Protection (CBP) to assist importers and exporters in meeting Federal requirements governing imports and exports. Brokers submit necessary information and appropriate payments to CBP on behalf of their clients and charge them a fee for this service.

Customs broker. “Customs broker” means a person who is licensed under this part to transact customs business on behalf of others.

Customs business. “Customs business” means those activities involving transactions with CBP concerning the entry and admissibility of merchandise, its classification and valuation, the payment of duties, taxes, or other charges assessed or collected by CBP on merchandise by reason of its importation, and the refund, rebate, or drawback of those duties, taxes, or other charges. “Customs business” also includes the preparation, and activities relating to the preparation, of documents in any format and the electronic transmission of documents and parts of documents intended to be filed with CBP in furtherance of any other customs business activity, whether or not signed or filed by the preparer. However, “customs business” does not include the mere electronic transmission of data received for transmission to CBP and does not include a corporate compliance activity.

Contact mitch@adhoclogistics.com for info about our copyrighted presentation “Exporting for Smart People”.

Electronic Export Information (EEI) filing has become routine for exporters and it is easy to “file it and forget it” once the submission has gone through.

Auditing EEI ((also referred to as AES) filings is a good business practice. If you are a self filer is anyone checking the accuracy of your submissions? Does your freight forwarder have an audit procedure in place if they are filing for you? Here is the risk:

§ 30.71 False or fraudulent reporting on or misuse of the Automated Export System.

(1) Failure to file; submission of false or misleading information. Any person, including USPPIs, authorized agents or carriers, who knowingly fails to file or knowingly submits, directly or indirectly, to the U.S. Government, false or misleading export information through the AES, shall be subject to a fine not to exceed $10,000 or imprisonment for not more than five years, or both, for each violation.

Are you aware of this potential filing error?

A common misconception is that EEI and Commercial Invoice value should match. However, inland freight and insurance charges must be accounted for in the EEI filing whether or not they are on the commercial invoice.

Contact mitch@adhoclogistics.com for assistance.

BIS (Bureau of Industry and Security) has recently revised their website making it a little easier to navigate. This is helpful. However, in my opinion, the CCL (Commerce Control List) remains difficult to use. The CCL Index is a good starting place but from there the reader is quickly in the weeds.

I’m reviewing and updating a Master Parts List for a client and am easily able to check HTS and Schedule B codes. ECCN (Export Control Classification Number) verification is a much longer process. Here is a link to Category 5- Telecommunications and Information Security as an example:

https://www.bis.doc.gov/index.php/documents/regulations-docs/2336-ccl5-pt1-3/file

The entire CCL consists of this type of incomprehensible documentation. BIS, how about revising the CCL to make it more user friendly? Anyone else agree with me?

Jill CliffordJill Clifford • President at FreightPlus | Strategic Planner for Innovative Transportation Solutions | Developing Efficient Transportation Strategies for C-Level LeadersPresident at FreightPlus | Strategic Planner for Innovative Transportation Solutions | Developing Efficient Transportation Strategies for C-Level Leaders

Let me guess:

You’ve received an LTL quote and you’re wondering why the prices seem high.

Here’s what’s probably happening:

Behind the scenes, carriers are factoring in so many variables beyond just mileage, incorporating things like:

*** Facility Accessibility ***

Mitch Kostoulakos, LCB • Ad Hoc Logistics LLC, Int’l Logistics Consultant/Licensed Customs Broker

I agree with all of these points. Also don’t withhold info about your shipping profile. In the absence of complete data carriers will hedge their bets.

Jill CliffordJill Clifford • 1st • 1stPresident at FreightPlus | Strategic Planner for Innovative Transportation Solutions | Developing Efficient Transportation Strategies for C-Level LeadersPresident at FreightPlus | Strategic Planner for Innovative Transportation Solutions | Developing Efficient Transportation Strategies for C-Level Leaders11m •    11m •

We take a non-traditional approach to sales at FreightPlus.

For us, it rarely leads with cost. Instead, our goal is figuring how transportation programs can strengthen a client’s business from the inside out.

It starts by studying their order cycle flow across all departments – from first purchase down through fulfillment, billing, and customer receipt. We dig into the process gaps that affect speed and experience.

Maybe unreliable carrier pickups slow down warehouse production.

Perhaps complicated tools that lack visibility disturb customer service updates.

Or unclear freight invoices cause problems with back-office paperwork.

We find and fix problems wherever they pop up. By improving our transportation plan, we make things better for the whole organization. Because it truly has a ripple effect – capacity stabilizes, the team gets more done, and customers get quicker responses.

Even though it might seem unusual, we prioritize making everything work well together before worrying about costs.

When orders go smoothly, the whole business does better.

Mitch Kostoulakos, LCB • Ad Hoc Logistics LLC, Int’l Logistics Consultant/Licensed Customs Broker

Exactly…demonstrate value before moving to price….Once price is under discussion it is difficult to go to value…

An annual customs review is a good business practice. Early January is a good time to get this done before day to day activity ramps up again. As part of your due diligence, check to make sure you are taking advantage of regulations that allow importing on a duty free or preferential basis. Here are a few basic items for your annual customs review:

Classification– review  updates to the HTSUS (Harmonized Tariff Schedule of the United States) to make sure your codes and descriptions are accurate. Proper classification and valuation of imported goods are the first step in compliance. If you do nothing else, do this.

Duty Drawback– this is a refund of duties paid on imports that are later exported. As supply chains expand there may be new opportunities for drawback. Record keeping is key here.

Chapter 98 of the Harmonized Tariff allows duty free entry of certain categories of goods. Examples are: American Goods Returned, American Goods Repaired or Altered Abroad, and American Components Assembled Abroad.

Trade agreements– programs which allow duty free or reduced duty rate entries. There are many agreements (such as USMCA) in place.

Customs rulings– consider requesting formal customs rulings prior to large transactions. This ensures compliance and eliminates uncertainty about imports. Rulings can be requested thru the CBP website.

Correcting errors– when an entry mistake is discovered it can be corrected by a prior disclosure to CBP. The formal process is a Post-Entry Amendment/Post Summary Correction. A prior disclosure can help mitigate penalties.

Contact mitch@adhoclogistics.com if you need help.

DEPARTMENT OF HOMELAND
SECURITY
U.S. Customs and Border Protection
New Date for the Spring 2024 Customs
Broker’s License Examination
AGENCY: U.S. Customs and Border
Protection, Department of Homeland
Security.
ACTION: General notice.
SUMMARY: This document announces
that U.S. Customs and Border Protection
has changed the date on which the
semi-annual examination for an
individual broker’s license will be held
to Wednesday, May 1, 2024.
DATES: The customs broker’s license
examination originally scheduled for
April 2024 will be held on Wednesday,
May 1, 2024.
FOR FURTHER INFORMATION CONTACT:
Omar Qureshi, Branch Chief, Broker
Management Branch, Commercial
Operations and Entry Division, Trade
Policy and Programs Directorate, Office
of Trade, (202) 909–3753, or
brokermanagament@cbp.dhs.gov.

Amalie Trade Compliance Consulting

Today’s Tuesday Trade Thought is for our Licensed Customs Brokers in the United States!
Once again, it is time to submit your Triennial Status Report. Every three years, starting from 1985, federal regulations specify that the Triennial Status Report is due by February 28th. Every individual and entity holding a valid broker’s license will need to submit a status report and the corresponding fee.

Mitch Kostoulakos, LCB •Ad Hoc Logistics LLC, Int’l Logistics Consultant/Licensed Customs Broker

Electronic filing is a big improvement