Let’s listen to the engineers.
As the infrastructure debate continues, here is some interesting info from ASCE (American Society of Civil Engineers). Take a look at your state’s infrastructure report card.
All posts by mitch
Freight Forwarder Guidance Part 2
I thought about this recent post after meeting with a well established freight forwarder this week. They are focused right now on finding capacity for imports from Asia in order to serve their clients. The current supply chain disruptions illustrate the importance of freight forwarder relationships. Expertise in compliance and documentation is certainly important but first they need to be able to move the freight.
NLR or License Exception?
NLR or License Exception?
NLR (No License Required) is not always appropriate for export transactions. Here is a useful guide to license exceptions:
A “license exception” is an authorization described in part 740 of the EAR that allows you to export, reexport or transfer in‐country under stated conditions, items subject to the EAR that would otherwise require a license.
Still Got Customs Delays?
In a recent post we discussed 3 common causes of customs delays: vague or incomplete descriptions, questionable valuations, and lack of IOR contact info on commercial invoices.
Those are the easy fixes. More difficult and frustrating customs issues involve country specific regulations that are not known prior to the transaction.
One of our more proactive clients asked Ad Hoc Logistics to research and develop a set of regulatory guidelines for 10 countries to which they export. This has helped prevent costly customs delays and time consuming follow up.
Why not be proactive when shipping to a new country? We can provide all the info you need.
Contact mitch@52.91.45.227
LinkedIn Post- Trucking Rates
Mitch Kostoulakos, LCBLicensed Customs Broker, International Logistics Consultant
The article cites driver shortage as a big factor in tight capacity and vaccinations may make more drivers available. Would be interesting to learn how much of this profit is being passed along to employees.
David J. DiSanto• 1stDiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization
LinkedIn Post- Inventory Lists
Mitch Kostoulakos, LCBLicensed Customs Broker, International Logistics Consultant
As shown in this article maintaining and updating inventory parts lists is a never ending job. If you have not already done so I recommend adding columns for HTS (Harmonized Tariff Schedule) or Schedule B codes for each part. This step will ensure that export documents and commercial invoices are accurate and help resolve any customs issues. I have assisted a number of clients with this task so reply if you would like to discuss.
Tony Rodriguez• 1stPresident & Owner, Daniel Penn Associates. LLC
EU Customs and VAT Changes
For those doing business in the EU, you need to be aware of new VAT regulations.
After July 1, 2021, every merchant selling, storing, or transporting goods through the EU will have to be EU VAT registered.
EAR99 and NLR? Maybe
In previous posts I have noted that many clients automatically enter EAR 99 and NLR when submitting EEI (Electronic Export Information) filings.
EAR 99 commodities fall under US Department of Commerce jurisdiction but are not listed on the CCL (Commerce Control List). NLR indicates No License Required.
Compliance best practices include at least annual verification of classifications. The CCL Index has been updated effective 05/20/2021. The list is alphabetical and easy to check so you may find that you should be using an ECCN (Export Control Classification Number) instead of EAR 99. Here is the link to the CCL Index:
https://www.bis.doc.gov/index.php/documents/regulations-docs/2329-commerce-control-list-index-3/file
Contact mitch@52.91.45.227 for help with export compliance.
Heads Up Exporters
In a recent post we discussed why auditing EEI 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 of a “file it and forget it” policy:
§ 30.71 False or fraudulent reporting on or misuse of the Automated Export System.
(a) Criminal penalties –
(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 these potential filing errors?
A common misconception is that EEI and Commercial Invoice value should match. This is actually not correct unless inland freight costs are added to both.
or
The new mandatory filing requirement in Section 758.1(b)(10) applies to all items that have an ECCN and are destined to China, Russia, or Venezuela, regardless of value, end use or end user.
For audits of your EEI filings contact mitch@52.91.45.227 .
Got Codes?
Have you ever entered the country code CH for a shipment to China? How about GE for Germany? Of course CH is the code for Switzerland. GE is the code for Georgia. The correct code for China is CN and for Germany is DE.
Here is a useful link to add to your bookmarks. It includes 2 and 3 letter ISO country codes, international calling codes, and IATA airport codes. Great maps too!
https://www.nationsonline.org/oneworld/country_code_list.htm