All posts by mitch

Regulatory Updates

Export Compliance = Risk Management

Posted on LinkedIn today:

If you are relying on your logistics service providers or your busy shipping department for export compliance you may be at risk. Both upper management commitment and front line training are essential parts of an Export Management & Compliance Program. While risk management always gets C level attention, export compliance is often a mid-management or lower level function.

Fines and penalties for violations should make export compliance a basic part of risk management. Best practices, including an EMCP, will reduce exposure to steep fines and penalties as described by BIS (Bureau of Industry and Security) on their website https://www.bis.doc.gov/.

BIS offers a number of on-line courses at no cost. Check them out under the Training and Compliance tab and get started!

Penalties Violators of the Export Administration Act of 1979, may be subject to both criminal and administrative penalties. When the EAA is in effect, criminal penalties can reach 20 years imprisonment and $1 million per violation.

Privileges A denial of export privileges prohibits a person from participation in any transaction subject to the EAR.

Nuts & Bolts

Got Wicked Problems?

Posted on LinkedIn today:

I came across the term “wicked problem” in the text for an International Supply Chain Management course. A wicked problem involves multiple stakeholders, each with different interests and values. As a result, there is no single common goal , no clear mission, and no universal solution. Any solution, after being implemented, will generate waves of consequences and can result in making the problem worse. A suggested framework for tackling a wicked problem consists of 4 levels of increasing complexity: Level 1- Process Engineering and inventory management. Level 2- Assets and Infrastructure. Level 3- Organizations and Inter-organizational networks. Level 4- the Macro Environment- PEST (Political, Economic, Social, and Tech). Fortunately, not all logistics problems are wicked problems. In most cases logistics problems are tactical and can be solved using Level 1 and 2 solutions. Supply chain issues are strategic and more complex so best suited to Levels 3 and 4. *Global Logistics & Supply Chain Management

Nuts & Bolts

Incoterms (continued)

Posted on LinkedIn today

Incoterms (continued) Contrary to popular belief Incoterms do not cover title to goods, ownership, or invoice payment. They do cover obligations of buyer and seller for payment for insurance, transport, export and import clearance, and division of other costs of storage or delivery. Incoterms will be updated again in 2020 by the International Chamber of Commerce.

Regulatory Updates

incoterms

Posted on LinkedIn today:

FOB really? A good commercial invoice includes clearly specified Incoterms. Incoterms are rules (not laws) used to facilitate global trade. They were created and are administered by the International Chamber of Commerce and are updated every 10 years. Incoterms 2010 published by ICC Services Publications, Paris. Did you know that, in the 2010 version of Incoterms, FOB applies only to ocean and inland waterway transport? Take the time to review your international documents for accuracy. For help contact Mitch@52.91.45.227

Nuts & Bolts

LinkedIn comment

William Cassidy  • 2nd

Senior Editor, Trucking and Domestic Transportation, The Journal of Commerce5d • EditedThe hashtag#bankruptcy of 101-year-old New England Motor Freight was a shock and a wake-up call for those who expected less volatility this year.

Mitch’s LinkedIn comment today:

Thoughtful analysis and right on target…traditional LTL carriers achieved efficiencies mostly thru managing labor costs…still important but real gains in efficiency will come via technology…

Nuts & Bolts

Customs broker exam

Published on LinkedIn today:

If you are planning to take the customs brokers exam in April you should be well into your preparations by now. The exam is not easy but a step by step study plan will give you confidence. I devised a simple method that worked well for me and will share it. E mail mitch@52.91.45.227 if interested.

Regulatory Updates

Exporting best practices

Posted on LikedIn today

When the ECCN (Export Control Classification Number) comes up on export documents many exporters automatically enter EAR 99. For license questions NLR (No License Required) is often used as a default exception. These may be the correct entries but it is a good business practice to check and confirm. While freight forwarders can provide expertise in these areas the exporter bears primary responsibility for compliance. If you are automatically using NLR and EAR 99 you may be at risk.

Regulatory Updates

Tariff Codes Best Practices

January is a good month to review harmonized codes. The United States International Trade Commission updates the Harmonized Tariff Schedule of the United States at least twice per year.

Using obsolete codes can result in customs delays and inaccurate  duty assessments 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?

For assistance contact mitch@52.91.45.227