Some takeaways from LM’s 2015 Rate Outlook Webinar today:
Air Cargo outlook according to Chuck Clowdis of IHS Global
Today I joined a BIS (Bureau of Industry and Security- Dept of Commerce) teleconference on the new export regulations for shipments to Cuba. As noted in a previous post, BIS has established a new license exception SCP- Support for the Cuban People. Two existing license exceptions, GFT and CTD, have been expanded. Following is a link to a list of FAQ’s regarding the new regs. As always, it is a good practice to check CFR 740.2, which covers restrictions on use of license exceptions. http://www.bis.doc.gov/index.php/policy-guidance/faqs?view=category&id=114#subcat181
Contact mitch@52.91.45.227 for assistance
BIS has issued new regulations for exporting from the US to Cuba. More to come on this as I plan to participate in BIS conference later this month. For help with export regulations contact mitch@52.91.45.227
Cuba – Amendment to EAR and Treasury Regulations
January 16, 2015 – The Bureau of Industry and Security published a rule in the Federal Register today to implement some of the changes in Cuba policy that the President announced on December 17, 2014. The rule makes changes to License Exceptions GFT and CCD. It also creates a new license exception Support for the Cuban People (SCP). It also creates case-by-case licensing policy for items for environmental protection of U.S. and international air quality, waters and coastlines. This was published simultaneously with a rule amending the Cuban Assets Control Regulations of the Department of the Treasury, Office of Foreign Assets Control.
The Addition of a New License Type (C62) for Support for the Cuban People (SCP) has been added to the Automated Export System
A new license type (C62) SCP was created in AES for the reporting of certain items exported and re-exported to Cuba that are intended to improve the living conditions of the Cuban people; support independent economic activity and strengthen civil society in Cuba; and improve the free flow of information to, from, and among the Cuban people.
If you are planning to take the customs brokers exam in April you should be well into your preparations by now. In a previous post I shared the prep strategies that worked for me. Here is the info again with the key steps highlighted. Best of luck but don’t rely on luck.
According to CBP Customs and Border Protection passing rates for the customs brokers exam average only 3-11% nationwide. The test is given twice per year in April and October. It consists of 80 multiple choice questions and a passing grade is 75%. The exam is open book which makes it seem easy. However, the books consist of the HTUS Harmonized Tariff of the United States and CFR 19 Code of Federal Regulations, totaling hundreds of pages. The difficulty is in being able to quickly access the right section for each question. It is a four hour exam so three minutes per question is not much time.
I took a prep course in Boston taught by Atty. Mary Wright. The class met two nights per week for 6 weeks prior to the exam. Mary explained the material very thoroughly from her background as a customs attorney and prior experience as an import specialist for CBP. We also reviewed previous exams in class. As good as this class was, I would not have been able to pass the exam without additional study. I estimate that I spent about 40-50 hours on weekends leading up to the exam.
I used 6 previous exams and a 3 step process. In step 1 I took each test for accuracy, ignoring the clock. In step 2 I took the tests again in the same order, while timing myself to make sure I could finish within 4 hours. I believe that step 3 was the key to my success. For this phase I circled all the questions I had missed in steps 1 and 2 and created a separate mini exam which I took several times until I answered all the questions correctly.
Schedule B codes have been updated for 2015. Best practices for exporters include checking to make sure Schedule B codes are up to date. Using obsolete or inaccurate codes can mean customs delays, onerous re-work and lengthy communications with customs agencies in destination countries, as well as possible fines and penalties. Take the time now to verify codes and update your parts lists.
For help contact mitch@52.91.45.227
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When the ECCN (Export Control Classification Number) comes up on export documents most shippers automatically enter EAR 99. For license questions NLR (No License Required) is often used as a default exception. While these may be the correct entries, it is a good business practice to check and confirm. Here is some info from a previous post.
As part of any Export Management Program, exporters need to make sure they are using correct commodity classifications and license exceptions. While freight forwarders can provide expertise in these areas the exporter bears primary responsibility for compliance. If you are automatically using NLR and EAR 99 you may be at risk. According to EAR part 732 “For items subject to EAR but not listed in CCL the proper classification is EAR 99. EAR 99 is a basket for items not specified under CCL and appears at the end of each Category on the CCL.”
If you need help contact mitch@52.91.45.227
This cohort was very diverse. In the beginning, they weren’t so sure about giving up their Friday nights and Saturdays. But as we proceeded, we heard time and again from these students how they wished they’d taken the course years ago!
I recently completed recertification of my CTL (Certified Transportation and Logistics) through AST&L (American Society of Transportation and Logistics). I believe that professional certifications are a valuable credential. Professionals prefer to do business with other professionals.