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“KNOW” BEFORE YOU SAY “GO” New Supply Chain Paradigm. Roger Clarke Williams Clarke Company, Inc. President rclarke@williamsclarke. com website: http://www.williamsclarke.com Chairman, Los Angeles Customs Brokers and Freight Forwarders Association Inc.
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“KNOW” BEFORE YOU SAY “GO”New Supply Chain Paradigm Roger Clarke Williams Clarke Company, Inc. President rclarke@williamsclarke. com website: http://www.williamsclarke.com Chairman, Los Angeles Customs Brokers and Freight Forwarders Association Inc. Director, National Customs Brokers & Forwarders of America, Inc.
Supply Chain Considerations To Mitigate Delays and Costs • Know who you are dealing with for both imports and exports • Logistics Challenges • Provide proper and complete documentation
Know who you are dealing with for both imports and exports • Verify the firm or individual your are negotiating with exists and are who they say they. Ask for some government verification documentation • Check the blocked, denied, entity and debarred persons list on the Customs and Border Protection and Bureau of Industry and Security websites: http://www.cbp.gov http://www.bis.doc.gov/dpl/default.shtm • Utilize trade professionals: brokers; forwarders; attorneys; consultants to help in the verification process • Keep accurate records of all communications • Review CBP trade publication web page http://www.cbp.gov/xp/cgov/newsroom/publications/trade/
Logistics Challenges • Analyze and plan for any special logistics requirement and define desired time frames • Consider possible carrier equipment and space problems • Government examination and requirements can cause delays and add substantial cost to goods movement • Customs and Border Protection (CBP) examinations Imports: • Non Intrusive Inspection (NII) - x-ray and magnetic imaging • Contraband Enforcement Team (CET) - drugs and security • Merchandise Enforcement Team MET) – commercial inspection
Logistics Challenges Exports • Intellectual Property Rights examinations • Possible commodity licensing by the Dept. of Commerce, Bureau of Industry and Security • Non-compliance with Automated Export System requirements will stop the export • Other Regulatory Agency Examinations • Department of Agriculture full devan examination • Fish & Wildlife inspection • Food and Drug Administration sampling and “Detention Without Physical Examination” • Consumer Product Safety Commission
Logistics Challenges • New government initiatives • Customs-Trade Partnership Against Terrorism (C-TPAT) • Secure Freight Initiative (SFI) • Container Security Initiative (CSI) • Importer Security Filing (ISF 10+2) • FDA Food Safety Initiative • Consumer Product Safety Act-U.S. Consumer Product Safety Commission • Lacey Act Amendments- new requirements and declaration relating to wildlife, fish, and plants. Both native and manufactured • Port environmental and infrastructure issues
Provide proper and complete documentation • Review Customs and Border Protection tips for new importers and exporters at: http://www.cbp.gov/xp/cgov/trade/trade_outreach/diduknow.xml • Review CBP publication “Importing into the United States” http://www.cbp.gov/linkhandler/cgov/newsroom/publications/trade/iius.ctt/iius.pdf • Work with trade professional to determine the proper Harmonized Tariff Schedule classification and declared valuation • Obtain a CBP binding ruling
Provide proper and complete documentation • Verify all pricing is correct and terms of sale is clearly displayed on the commercial invoice: FOB; C&F; CIF; DUP; DDP • Commercial invoice must indicate costs, discounts, assets, commission must be shown • Ocean freight paid, importer responsible for verification if requested by CBP • Insurance premium amount if applicable • Any selling or buying commission if applicable • Any assists both physical or financial • Indicate if purchased or sold on consignment • Indicate if transaction is conducted by related parties • Complete and accurate description of each item in the shipment
Provide proper and complete documentation • Packing List • Quantity • Packaging • Weight • Check Customs Rulings Online Search System (CROSS) http://rulings.cbp.gov/index.asp?ac=about • Other documents necessary to determiner merchandise admissibility • Other regulatory agency documentation
Let’s “GO” now that you “Know” • Importing and exporting is not rocket science. With a little planning and research problems can avoided and a successful transaction can be accomplished • Make use of all available resources • Use trade professional for not only the actual operational requirements but also for preplanning and consolation • Keep accurate and complete records • Plan for the unexpected