Forced Labor is an important issue for importers and customs brokers to understand and it is complex. I decided to educate myself on the topic and found a good overview and set of resources on the CBP website. Here is the link:

https://www.cbp.gov/trade/forced-labor

In the 19th Century boilerplate meant rolled steel templates used to make boilers and the printed material on the plates.

Today, the term boilerplate refers to standardized text, copy, documents, methods, or procedures that may be used over again without making major changes to the original. Boilerplate is commonly used for efficiency and to increase standardization in the structure and language of written or digital documents.

Traders when was the last time you reviewed your Commercial Invoice for accuracy or updates? Chances are it has been quite a while, given the more immediate challenges in logistics today. The same question applies to documents produced by your freight forwarder. Checking your CIs for accuracy is a best practice and can help reduce customs delays. Reviewers with “fresh eyes” are an even better idea.

While there is no universal standard format for commercial invoices, including the following key elements will help reduce customs delays and entry mistakes:

Description of goods – Vague or incomplete descriptions are the most common cause of customs delays. Avoid trade names, brand names, jargon. What is it? What is it made of? What is it used for?

Recipient or Importer of Record contact info- customs delays are often prolonged by slow communication between CBP and importers or between exporters and customs agencies in other countries. Make sure phone and e mail info is spelled out on the CI.

Invoice Number, Page Numbers – Avoids confusion for entries with multiple CIs or CIs with multiple pages.

Country of Origin– Best to use ISO country codes.

Related/Not Related parties

Incoterms and currency- these are elements of the sales contract. Indicate version of Incoterms (2010, 2020) as all parties may not be aware of updates.

Harmonized tariff code to the 6 digit level– if unsure best not to include this info.

Summary of Value- must include IV Invoice Value. Can also include NDC Non Dutiable Charge (subtractions), AMMV Add to Make Market Value (additions), NEV Net Entered Value (bottom line- dutiable).

For immediate assistance contact mitch@adhoclogistics.com

I am pleased to accept appointment to the Merrimack Valley Regional Transit Authority (MVRTA) advisory board as Selectmen’s designee for the Town of Merrimac.

I’ve always loved baseball and attribute my math skills to studying the back of favorite players’ cards. The basic statistics were batting average, home runs, and rbi for hitters. For pitchers it was wins-losses and earned run average. These measures don’t even scratch the surface compared to the sabermetrics used in today’s game.

Logistics and baseball have some common features. We play every day, errors can have a big impact , managers get criticized, and there are plenty of rules and regulations. Like sabermetrics in baseball, we can measure logistics performance in many different ways.

Measuring and managing logistics performance is a full time job for professionals and the volume of data can be daunting. Managers in other functions such as finance, marketing, or manufacturing may need a quick view of logistics data as it relates to their responsibilities.

Here are a few general measures for the dashboard:

Absolute Performance- monitor absolute logistics failures rather than percentages. For example, 99.5% on time performance appears very good. However, in a high volume operation, it could mean hundreds or thousands of late orders per day.

Inventory Turnover- common measurement in asset mgt.

Order Fill Rate- customer service and warehouse productivity measurement. Can also use item, line, or value fill rate.

Warehouse Utilization %- indicator of good asset mgt.

Warehouse Productivity- measure of units received, stored, picked, packed, and shipped per hour.

Order Cycle – reduced order cycle means less inventory in the system and greater customer satisfaction. Longer order cycle means more inventory in the system and reduced customer satisfaction.

Lost Sales- inverse relationship with inventory. Higher inventory costs, lower risk of lost sales. Lower inventory costs, higher risk of lost sales.

Transportation costs- always a trade off….bulk shipments can reduce transportation costs but leads to higher inventory levels in system. Higher transportation costs due to mode shift (air vs. ground or air vs. ocean) can reduce inventory in system by shortening the order cycle.

Commodity value- higher dollar value means increased transportation, inventory, and packaging costs.

Density of product- High density (lbs/ cubic ft or kgs/ cubic meter) means lower transportation and inventory costs since the product takes up less space in containers or warehouse.

Loss and Damage- greater susceptibility to loss or damage means higher transportation rates and higher warehousing costs due to special handling.

Location Decision- Distance from sources or markets = relative advantage or disadvantage vs. competitors. This is a C level responsibility.

Need help? contact mitch@52.91.45.227

https://www.linkedin.com/posts/activity-7035240457882206208-oTJO?utm_source=share&utm_medium=member_desktop

Mike, can you give a brief explanation of what double brokering is? Thanks

Hi Mitch, it can be a couple things but 90 percent of the time it’s a carrier who is on a load board that is asking to haul your load as a broker who then in turn hands the load off to another carrier. When this happens, the original carrier who is posing as an asset carrier then usually doesn’t pay the actual carrier who hauled the load and it creates a lot of issues with freight liability as well. Because basically a criminal is involved and is scamming you and the carrier. It’s really bad and it’s out of control rampant now. Scammers have figured out how to work the system. Not enough checks and balances.

Our international travels resumed in 2022 after a two year hiatus. The challenges involved in air travel are well known and it is wise to be prepared for flight delays so they don’t spoil your entire trip.

We just renewed our Global Entry enrollment for another 5 years. The cost ($100 for 5 years) is well worth it. Global Entry, which includes TSA pre-check, enables the traveler to avoid long customs lines upon returning to the US after a tiring trip. Here is the link if you are interested:

https://www.cbp.gov/travel/trusted-traveler-programs/global-entry

Next up Portugal, Spain, and as always, Canada.

David Noah

President at InterMart, Inc.

Companies that allow employees or contractors to take commercial items across a border—known as a hand carry—are taking on a big compliance risk. Here’s what you need to know to stay compliant.

Mitch Kostoulakos, LCB

Excellent post David. I think most hand carries are treated casually without much thought to the risk.

In previous posts we have noted 3 common causes of customs delays: vague or incomplete descriptions, questionable valuations, and lack of IOR contact info on commercial invoices. These are the easy fixes. The real complexity in international trade is due to the many different regulations applying to destination countries.

Customs delays in other countries are problematic for exporters, 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

Contact mitch@52.91.45.227 for help.

Customs Broker Permit User Fee as payment is due no later than February 24, 2023. The fee is $163.71 for each permit held.

Nice to pay for just one permit this year.

Nerd: “socially awkward” and “an intelligent but single-minded person obsessed with a nonsocial hobby or pursuit” Geek: “a digital-technology expert or enthusiast” and “a person who has excessive enthusiasm for and some expertise about a specialized subject or activity”. Compliance folks sometimes refer to themselves as Geeks.

Demand for compliance professionals has never been higher, as LinkedIn users can readily see. Companies of all sizes and in all industries realize that being in compliance means fewer supply chain disruptions. At the very least compliance is good risk management. Think of it as insurance.

Compliance is about attention to detail, consistency, process, and oversight. I guarantee that your compliance folks are not trying to practice “sales prevention”. The goal is to complete transactions the right way, avoid customs or logistics delays and reduce exposure to fines and penalties. However, there is no doubt that complying with all of the agencies involved in international trade generates a lot of red tape and can be frustrating.

Compliance managers must have the authority to stop shipments when red flags appear. In order to ensure independence compliance folks should not be in the supply chain, finance, or marketing chain of command. Better reporting relationships would be with the legal department, CEO, or COO.

Consider just a few of the details that can make or break a smooth transaction:

Harmonized Codes to the full 10 digits including heading and sub heading. It is very easy to transpose digits.

Schedule B Codes, ditto

ECCN , Alpha numeric, number, letter, followed by 3 numbers. Example 4A994. Then followed by sub paragraph level and don’t forget the dot between the last number and the sub para.

License Exceptions are designated by 3 letter codes and must be compatible with the ECCN listed.

COO, Country of Origin markings and proper codes on documents and AES filings. Best not to guess here. Have you ever entered CH for China?

Valuation must be determined accurately and is best covered in a separate post which I have done on 05/09/2019.

These tactical elements are just some of the basics. We could also mention commodity descriptions, red flag screening, and plenty of other details. Trade policy is more strategic, encompassing trade agreements, incoterms, and dealing with enforcement agencies. There is a lot at stake so, hats off to the compliance teams.

For assistance contact mitch@52.91.45.227