Schedule B codes have been updated for 2015. Best practices for exporters include checking to make sure Schedule B codes are up to date. Using obsolete or inaccurate codes can mean customs delays, onerous re-work and lengthy communications with customs agencies in destination countries, as well as possible fines and penalties. Take the time now to verify  codes and update your parts lists.

For help contact mitch@52.91.45.227

When the ECCN (Export Control Classification Number) comes up on export documents most shippers automatically enter EAR 99. For license questions NLR (No License Required) is often used as a default exception. While these may be the correct entries, it is a good business practice to check and confirm. Here is some info from a previous post.

As part of any Export Management Program, exporters need to make sure they are using correct commodity classifications and license exceptions. 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.  According to EAR part 732 “For items subject to EAR but not listed in CCL the proper classification is EAR 99. EAR 99 is a basket for items not specified under CCL and appears at the end of each Category on the CCL.”

If you need help contact mitch@52.91.45.227

Do you want to get a handle on export compliance in 2015? Implementing a formal Export Management Compliance Program can be quite intimidating and expensive, especially for small and medium sized companies. An EMCP requires a significant commitment of time  on the part of management and usually involves hiring an outside consultant for the initial set up. There is no question that a written EMCP is a good investment for any company to make. An EMCP establishes clear accountability, written instructions, and reduces risk of non compliance. If the exporter has not experienced problems or incurred any fines it is easy to make an EMCP a “back burner” issue. If your company has not implemented an EMCP it is still good business practice to take some basic compliance steps. While these steps cannot take the place of a written EMCP they will help reduce risk of non compliance.  To get started I suggest the following:

• Review and confirm correct Harmonized and Schedule B codes
• Check EAR regulations for correct exception codes and license or NLR designations
• If exporting under ITAR you need a responsible trained officer
• Check common “Red Flags” such as denied parties lists, entities lists, and unverified lists
• Review export documentation for possible improvements

Contact mitch@52.91.45.227 for help.

 In a previous post I discussed Red Flags to be aware of in export transactions. Here is more detail from the Bureau of Industry and Security about the Consolidated Screening List. The Department of Commerce lists that are included in the Consolidated Screening List are: Denied Persons List, Unverified List, and Entity List. For help with export compliance contact mitch@52.91.45.227

Consolidated Screening List

Prior to taking any further actions, users are to consult the requirements of the specific list on which the company, entity or person is identified by reviewing the webpage of the agency responsible for such list. The links below will connect you to the specific webpage where additional information about how to use each specific list is contained.

Department of Commerce – Bureau of Industry and Security

Here is a list from the Bureau of Industry and Security (BIS) website of things to look for in an export transaction. My next post will discuss “Lists of Parties of Concern” including “Denied Persons”.  Make sure you are not doing business with the bad guys. A little due diligence up front saves a lot of trouble later on.

• The customer or its address is similar to one of the parties found on the Commerce Department’s [BIS’] list of denied persons.
• The customer or purchasing agent is reluctant to offer information about the end-use of the item.
• The product’s capabilities do not fit the buyer’s line of business, such as an order for sophisticated computers for a small bakery.
• The item ordered is incompatible with the technical level of the country to which it is being shipped, such as semiconductor manufacturing equipment being shipped to a country that has no electronics industry.
• The customer is willing to pay cash for a very expensive item when the terms of sale would normally call for financing.
• The customer has little or no business background.
• The customer is unfamiliar with the product’s performance characteristics but still wants the product.
• Routine installation, training, or maintenance services are declined by the customer.
• Delivery dates are vague, or deliveries are planned for out of the way destinations.
• A freight forwarding firm is listed as the product’s final destination.
• The shipping route is abnormal for the product and destination.
• Packaging is inconsistent with the stated method of shipment or destination.
• When questioned, the buyer is evasive and especially unclear about whether the purchased product is for domestic use, for export, or for re-export.

For help with export compliance contact mitch@52.91.45.227