Monthly Archives: January 2024

Nuts & Bolts

Checked EEI Lately?

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.

Regulatory Updates

New Year Due Diligence

I frequently conduct no fee discussions (phone or Zoom) with new clients to determine if I can help them. They may be unsure about their HTS codes or a specific regulation. Codes change frequently so it is a good business practice to verify your data.

Exporters quite often assure me that their commodities fall under EAR 99 and NLR (No License Required). While this may be true, due diligence requires verification, which starts with checking ECCN (Export Control Classification Number). BIS (Bureau of Industry and Security) spells out the specific procedures for checking ECCN and licensing requirements. The CCL (Commerce Control List) Index is a good place to start.

https://www.bis.doc.gov/

https://www.bis.doc.gov/index.php/documents/regulations-docs/13-commerce-control-list-index/file

EAR99 Does Not Always Mean NLR

If your item falls under U.S. Department of Commerce jurisdiction and is not listed on the CCL, it is designated as EAR99. EAR99 items generally consist of low-technology consumer goods and do not require a license in most situations. However, if your proposed export of an EAR99 item is to an embargoed country, to an end-user of concern, or in support of a prohibited end-use, you may be required to obtain a license.

Don’t assume- verify!

Contact mitch@adhoclogistics.com for immediate assistance.

Nuts & Bolts

Reading the CCL

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?

Regulatory Updates

Heads Up- Tariff Updates

The HTS (Harmonized Tariff Schedule) and Schedule B have been updated for 2024. Both publications show multiple pages of code changes. Due diligence in checking your codes at least annually is a best practice for importers and exporters. Make sure that you are not using obsolete codes to avoid customs delays and possible penalties.

Here are the HTS and Schedule B links. You can check individual codes or review the change records.

https://hts.usitc.gov/

https://www.census.gov/foreign-trade/schedules/b/2024/index.html

As a reminder HTS codes can be used for AES filing, with some exceptions, per the following:

NOTICE TO EXPORTERS

For reporting electronic export information in the Automated Export System (AES), the statistical reporting numbers in the HTS (with their respective descriptions and units of quantity) for articles falling in chapters 1 through 97 may be used in place of those in the Schedule B, except as noted below.

Contact mitch@adhoclogistics.com for assistance.

Nuts & Bolts

LinkedIn Comment- LTL Quotes

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 ***

View Mitch Kostoulakos, LCB’s profile

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.