All posts by mitch

LinKedIn Comments

Glynn Lloyd• 2ndExecutive Director at The Foundation for Business Equity

I don’t understand why our corporate leaders are not willing to invest in the betterment of this country. It is time for those who get it to stand up. I, for one, as a small business owner support paying a little more taxes to support the infrastructure my business relies on, but more importantly to contribute my fair share to build an equitable and less extractive economy.

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

I agree and posted on this topic yesterday

Invest In Infrastructure

https://source.asce.org/asces-2021-report-card-marks-the-nations-infrastructure-progress/

The American Society of Civil Engineers has issued it’s 2021 Report Card for America’s Infrastructure. It is an interesting read. The overall grade is C- and trending up. No one in the transportation business will be surprised that Roads scored a D.

With C- being an upward trend it shows the poor condition of our infrastructure and how much work remains to be done. In fact, the overall score would be worse if not for B and B- for Rail and Ports.

I have traveled on roads in most EU countries and found them to be in much better shape than ours. The ASCE report notes that the upward trend in overall score can be attributed to increased investment to date. No doubt that, whatever our political views, we can agree that additional investment is urgently needed. Infrastructure won’t fix itself!

LinkedIn Comment

David J. DiSanto• DiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization4h • 

Good luck with increasing your private fleet….DG

The driver shortage, aggravated by the coronavirus pandemic, is reverberating throughout the trucking industry. The problem has reached the point where fleets are noting a shallower pool of independent drivers.
“The available pool of independent contractor drivers is smaller than it has been historically,” Truckload carrier Marten Transport stated in its annual report, filed March 1 with the Securities and Exchange Commission.

https://www.transportdive.com/news/dollar-general-logistics-private-truck-fleet/597183/?utm_source=Sailthru&utm_medium=email&utm_campaign=Issue:%202021-03-29%20Transport%20Dive%20%5Bissue:33271%5D&utm_term=Transport%20Dive

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

I agree with you Dave. I’m sure DG has done their due diligence. However, a private fleet is a risky move and just as likely to add costs rather than reduce them. A couple of big questions: Will drivers be company employees with full benefits? Will the fleet have access to back hauls or will there be significant deadheading?

Screen Yourself

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

Here is some more info from the BIS website:

What does EAR99 mean?

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.

Contact mitch@52.91.45.227 for assistance

LinkedIn Comments

#internationaltrade

Post from Ira Kawaller

https://igkawaller.medium.com/trade-policy-reconsidered-c7b1f780b86c

The transition to a new administration offers the opportunity to review federal priorities with respect to international trade policies. Reconsideration of our use of tariffs should be at the top of the list.

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

Well said. This post clearly and concisely states the view that tariffs burden US consumers and businesses more than other parties. Using tariffs to punish or retaliate is poor trade policy.

Country Commercial Guides

How About Those Regulations ?

My last post was about AEC/EEI filing for US exports, which has become routine for most shippers. The real complexity in international trade is the many different regulations applying to destination countries.

Customs delays in other countries are problematic, requiring a lot of time and effort to resolve. Best practices in exporting include due diligence and research when shipping to a country for the first time. The Country Commercial Guides published by the International Trade Administration are an excellent no cost starting point. Here is the link:

https://www.trade.gov/ccg-landing-page

LinkedIn Comments

Michael DeMarco• Licensed Freight Broker and 3PL specializing in FTL | LTL | First and Final Mile | Drayage | Project Cargo. With old fashioned customer service we help shippers and logistics companies keep their supply chains moving.

Freight Class. If you are a shipper it would be very wise to know and understand this process. This is the single most important factor when determining LTL rates. It is also the single largest issue when a shipper is hit for overages on a shipment. Incorrect freight classes will get you into a lot of trouble. 


Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

Good advice, Mike. Just like with HTS codes don’t assume – verify.

LinkedIn Comments

U.S. Department of Commerce

Small, medium, and large businesses all have the amazing opportunity to expand internationally, however, there are several steps that must be taken to ensure that your company is ready to export. the International Trade Administration shares information on getting started here:

https://www.trade.gov/learn-how-export

Mitch Kostoulakos, LCB Licensed Customs Broker, International Logistics Consultant

Excellent resources for businesses

Alphabet Soup

EEI, AES, ACE, SED

By now most exporters are quite familiar with electronic export information filing. The old yellow paper SEDs are long gone. Some shippers self file but many rely on their freight forwarders. In either case it is a best practice to audit your submissions on a regular basis to ensure accuracy and avoid fines and penalties.

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. Here is the relevant language from 15CFR Part 30.6

(17) Value. In general, the value to be reported in the EEI shall be the value of the goods at the U.S. port of export in U.S. dollars. The value shall be the selling price (or the cost, if the goods are not sold), plus inland or domestic freight, insurance, and other charges to the U.S. seaport, airport, or land border port of export. Cost of goods is the sum of expenses incurred in the USPPI’s acquisition or production of the goods. Report the value to the nearest dollar, omit cents. Fractions of a dollar less than 50 cents should be ignored, and fractions of 50 cents or more should be rounded up to the next dollar.

Ad Hoc Logistics can audit your filings, checking all elements of the EEI for errors. A confidential report will be provided for internal follow up. Contact mitch@52.91.45.227 for immediate assistance.