All posts by mitch

Comment in International Trade Compliance Experts

 

Mitch Kostoulakos commented on a discussion in International Trade Compliance Experts: Networking Group.

  • Mitch Kostoulakos Good article…What are the best certification programs for export compliance?

Comment on Talking Logistics.com

Mitch Kostoulakos I agree with Russ Romine’s comments. In terms of risk management I would add export and import compliance issues. Many small and medium sized companies tend to either ignore compliance or assume that their forwarder is handling for them. 1m ago

Comment in Logistics Consulting

Mitch Kostoulakos

Mitch Kostoulakos commented on a discussion in Logistics Consulting.

  • Mitch KostoulakosMitch Kostoulakos I agree that customer service is at least inconsistent. Providers are driving productivity in operations and this extends to customer service. Clients can improve their customer experience however. See my post  Customer Service Blues @ adhoclogistics.com more 31s ago

Comment on AST&L certification

Here is my comment on a discussion in American Society of Transportation and Logistics astl.org

 

  • Mitch Kostoulakos

    International Logistics and Regulatory Consulting

    AST&L certification process is rigorous as is APICS. I would say that AST&L is for logistics and transportation practitioners while APICS includes inventory and procurement. I value my CTL but agree with the comments that it is not widely recognized. AST&L needs to raise the profile to the same level as APICS certification. Professionals looking for advanced education need to be practical about how they use their time and must consider how the certificate will help their career.

 

Best Practices in Global Classification Compliance

This afternoon I participated in a webinar presented by Customs Info/Descartes on “Best Practices in Global Classification Compliance”. The first half of the webinar consisted of a good refresher about classification compliance. The Customs Modification Act requirement of reasonable care was defined as a solid process of research support and documentation. The presenter reminded the audience that:

  • Classification is subjective- tariff schedules do not necessarily keep up with technology
  • Customs definitions can differ from industry definitions
  • Different interpretations exist between countries and also between ports within the same country

 

The basic components of a best in class process are:

  1. Break down items from universe into groups
  2. Research- even if you think you know the correct classification    customsinfo.com is a good tool
  3. Identify necessary info needed for classification such as materials, dimensions, intended use, etc
  4. Documentation- needed to support your determination
  5. Automation- implementing a software classification tool will improve efficiency and productivity
  6. On-going maintenance and monitoring for changes in HTS binding rulings and in your products is essential

 

Supporting documentation includes

  • spec sheets, drawings, photos
  • info requests from engineers, scientists, chemists, etc
  • HTS chapter and section notes that apply to your product
  • explanatory notes
  • informed compliance publications
  • customs rulings that apply to your product
  • record keeping (5 years)

 

Contact Ad Hoc Logistics for help with classification and compliance.

 

More Export Compliance Basics

Many exporters automatically enter EAR 99 on their shipping documents without really knowing what this designation means. EAR 99 is a basket category for items that are subject to the EAR (Export Administration Regulations) but not on the CCL (Commerce Control List).  The CCL lists “controlled” items which may require a license for export. The CCL is made up of a classification of items by ECCN (Export Control Classification Number).  So a basic export compliance step is to verify if your items are “controlled” needing an ECCN or if they can be shipped under EAR 99. If an ECCN is listed you then need to determine if a license is required by checking “Reasons for Control” and destination country lists. There are 3 ways to determine an ECCN:

1) Check with the manufacturer, producer, or developer.

2) Self classify using the CCL.

3) Official request to BIS (Bureau of Industry and Security) using the SNAP-R tool @ bis.gov

 

Contact adhoclogistics.com for help in determining your ECCN.

Customer Service Blues

In previous posts I discussed basic logistics KPI’s such as % of on time delivery, warehouse fill rates, and loss/damage experience. KPI’s are essential to the management of logistics providers as well as their clients. Some customer service functions, however, are not as easy to measure. Clients of logistics providers include shippers, consignees, importers, and exporters. Whether your logistics provider is a motor carrier, freight forwarder, customs broker, or warehouse company, you will need customer service assistance from time to time. Let’s differentiate:

Request for Information– shipment status, tracking and tracing, claims status, rate requests, invoice balance. This type of customer service is best obtained on line. Take the time to become familiar with your providers’ info systems so you don’t waste time on the phone or waiting for a call back. If your provider does not offer this type of info on line they are either inefficient or very small. To avoid frustration ask yourself if you just need information or action by your provider. Information is easier to get than action.

Action Needed- This level of customer service most likely requires human intervention. Examples include customs or regulatory delays, stopping or diverting shipments, credit issues, special pricing, or real emergencies. While no one likes calling an 800 number, it is a good idea to get your request into the provider’s system as soon as possible as a first step. The difficulty is in reaching the right contact and getting the action you need. If you use a 3PL you may be able to delegate the problem for their handling and have them provide timely updates. If you do not use a 3PL, then you need to manage the issue on your own. One mistake clients make is to rely on their  account rep for all customer service. Account reps are usually on the road and in meetings so this causes delays in action. Another mistake is to depend on the super efficient Mary, Debbie, Tom, or Bill in your provider’s office. Everyone takes vacations and sick days so don’t rely on one person for your customer service needs. A better way to get good customer service is to establish protocols with the help of your providers.

Protocols- Day to day logistics consists of planning, execution, and problem solving. Good planning is essential but not foolproof. Logistics managers deal with changing schedules, equipment failures, weather delays, regulatory issues, and miscommunication on a daily basis. Most problems, however, are not new. The same situations tend to repeat themselves so they can be anticipated. I suggest developing a set of problem solving protocols for the most common issues in your supply chain. This approach will save you time since you will not be starting from scratch when a problem arises. It will also enable your colleagues to act in your absence. A basic protocol defines the problem and lists steps to be followed as well as the resources involved. Your logistics providers can help by providing resources. They should be willing and able to give you relevant operations contacts along with phone and e mail info for your identified problem areas. Your account rep may be surprised when you ask for help developing protocols but they should welcome the opportunity. This method can be a big time saver for them as well. Get commitment from your providers to respond to your requests in an agreed to amount of time. You can update the protocols as needed. Make protocols a part of your meetings with your account reps and you will get better customer service.

Finally, if your account rep says “Just call me”, don’t accept this response.

We help small and medium sized companies stay compliant with Customs and export regulations and manage logistics. Contact mitch@52.91.45.227

 

Export Compliance (cont.)

In a previous post I discussed the importance of an Export Management Compliance Program. Implementing an EMCP is a major undertaking so it is often delayed for lack of resources. While you may be in this position, there are still valid export compliance steps that you can take. The first step in export compliance is to review Schedule B codes used for export and confirm that AES entries are correct. On 6/24 I participated in a Census Bureau webinar titled “The Basics of Export Compliance: Classifying Your Product”. This training proved to be a good review for me and would be very helpful for export compliance novices. Topics covered included:

  • Schedule B search engine demo
  • How to use headings
  • Difference between Harmonized codes and Schedule B
  • In depth discussion of the 6 General Rules of Interpretation
  • “Essential Character” defined
  • “End Use” determination

 

Ad Hoc Logistics can help your company with export compliance. If you need help with Schedule B codes contact  adhoclogistics.com