All posts by mitch

True North

Canada Border Services Agency (CBSA) has updated their Customs Tariff for 2021.

Canada is the United States’ largest trading partner for exports and 3rd largest for imports. Here is a link to the Canada Customs Tariff 2021. For 10 digit harmonized codes, the first 6 are universal and the last 4 differ from country to country.

https://www.cbsa-asfc.gc.ca/trade-commerce/tariff-tarif/2021/menu-eng.html

CBSA maintains a robust, user friendly website. Here are several links that may be helpful for traders:

https://www.cbsa-asfc.gc.ca/agency-agence/program-eng.html

https://www.cbsa-asfc.gc.ca/export/guide-eng.html

https://www.cbsa-asfc.gc.ca/import/guide-eng.html

https://www.cbsa-asfc.gc.ca/import/courier/lvs-efv/menu-eng.html

A Little Management

Many of my clients are hard-working owners or operators of small businesses. They don’t have in-house compliance or logistics expertise so must wear several hats. Day to day activities or unexpected issues take up most working hours. As a result, functions such as logistics planning and import/export compliance are often unmanaged.

Making sure that your business is in compliance with import and export regulations is good risk management as well as good business. Think of it as insurance. I have written about compliance as risk management in previous blog posts. Here is an example:

Contact mitch@adhoclogistcs.com for immediate assistance or an initial discussion.

January Due Diligence

An annual customs review is a good business practice. Another good practice is to make sure you are taking advantage of regulations that allow importing on a duty free or preferential basis. Here are a few basic items for your annual customs review.

 Contact mitch@52.91.45.227 if you need help.

Classification– review annual updates to Harmonized Tariff to make sure your codes and descriptions are accurate. Proper classification and valuation of imported goods are the first step in compliance. If you do nothing else, do this.

Duty Drawback– this is a refund of duties paid on imports that are later exported. As supply chains expand there may be new opportunities for drawback. Record keeping is key here.

Chapter 98 of the Harmonized Tariff allows duty free entry of certain categories of goods. Examples are: American Goods Returned, American Goods Repaired or Altered Abroad, and American Components Assembled Abroad.

Trade agreements– programs which allow duty free or reduced duty rate entries. There are many agreements (such as USMCA) in place.

Customs rulings– consider requesting formal customs rulings prior to large transactions. This ensures compliance and eliminates uncertainty about imports. Rulings can be requested thru the CBP website.

Correcting errors– when an entry mistake is discovered it can be corrected by a prior disclosure to CBP. The formal process is a Post-Entry Amendment/Post Summary Correction. A prior disclosure can help mitigate penalties.

Heads Up … HTS updated

Happy New Year!

January is a good month to review harmonized codes. The United States International Trade Commission has updated the Harmonized Tariff Schedule of the United States effective January 1, 2021. There are numerous HTS code revisions with the change record totaling 37 pages.

Using obsolete codes can result in customs delays, inaccurate  duty assessments, or fines and penalties, so it is a good business practice to check the tariff.

While you are at it are you sure EAR99 and NLR apply to your exports? Don’t assume, verify.

For assistance contact mitch@52.91.45.227

What Does EAR99 Mean?

While assisting a client this week they made a common, but inaccurate, assumption that if their commodity is classified for export as EAR99 then NLR (No License Required) automatically applies. Not necessarily.

Here is some info from the BIS (Bureau of Industry and Security) 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