NLR or License Exception?
NLR (No License Required) is not always appropriate for export transactions. Here is a useful guide to license exceptions:
A “license exception” is an authorization described in part 740 of the EAR that allows you to export, reexport or transfer in‐country under stated conditions, items subject to the EAR that would otherwise require a license.
In a recent post we discussed 3 common causes of customs delays: vague or incomplete descriptions, questionable valuations, and lack of IOR contact info on commercial invoices.
Those are the easy fixes. More difficult and frustrating customs issues involve country specific regulations that are not known prior to the transaction.
One of our more proactive clients asked Ad Hoc Logistics to research and develop a set of regulatory guidelines for 10 countries to which they export. This has helped prevent costly customs delays and time consuming follow up.
Why not be proactive when shipping to a new country? We can provide all the info you need.
Contact mitch@52.91.45.227
Mitch Kostoulakos, LCBLicensed Customs Broker, International Logistics Consultant
The article cites driver shortage as a big factor in tight capacity and vaccinations may make more drivers available. Would be interesting to learn how much of this profit is being passed along to employees.
David J. DiSanto• 1stDiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization
Mitch Kostoulakos, LCBLicensed Customs Broker, International Logistics Consultant
As shown in this article maintaining and updating inventory parts lists is a never ending job. If you have not already done so I recommend adding columns for HTS (Harmonized Tariff Schedule) or Schedule B codes for each part. This step will ensure that export documents and commercial invoices are accurate and help resolve any customs issues. I have assisted a number of clients with this task so reply if you would like to discuss.
Tony Rodriguez• 1stPresident & Owner, Daniel Penn Associates. LLC
In a recent post we discussed why auditing EEI filings is a good business practice. If you are a self filer is anyone checking the accuracy of your submissions? Does your freight forwarder have an audit procedure in place if they are filing for you? Here is the risk of a “file it and forget it” policy:
§ 30.71 False or fraudulent reporting on or misuse of the Automated Export System.
(a) Criminal penalties –
(1) Failure to file; submission of false or misleading information. Any person, including USPPIs, authorized agents or carriers, who knowingly fails to file or knowingly submits, directly or indirectly, to the U.S. Government, false or misleading export information through the AES, shall be subject to a fine not to exceed $10,000 or imprisonment for not more than five years, or both, for each violation.
Are you aware of these potential filing errors?
A common misconception is that EEI and Commercial Invoice value should match. This is actually not correct unless inland freight costs are added to both.
or
The new mandatory filing requirement in Section 758.1(b)(10) applies to all items that have an ECCN and are destined to China, Russia, or Venezuela, regardless of value, end use or end user.
For audits of your EEI filings contact mitch@52.91.45.227 .
Have you ever entered the country code CH for a shipment to China? How about GE for Germany? Of course CH is the code for Switzerland. GE is the code for Georgia. The correct code for China is CN and for Germany is DE.
Here is a useful link to add to your bookmarks. It includes 2 and 3 letter ISO country codes, international calling codes, and IATA airport codes. Great maps too!
https://www.nationsonline.org/oneworld/country_code_list.htm
The ongoing infrastructure debate calls to mind the term “wicked problem” from a noted supply chain management text*.
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– This is the engineering approach focusing on what is being carried (work, cash, information) and process design within and between organizations. Risk management is about improved visibility and control.
Level 2- Assets and Infrastructure- This is the insurance and financial approach. Nodes and links are examined and strengthened to avoid disruptions along the supply chain.
Level 3- Organizations and Inter-organizational networks– this is strategic level problem solving involving outsourcing, partnering, and offshoring.
Level 4- the Macro Environment- This level uses PEST (Political, Economic, Social, and Technological) analysis of environmental changes. Issues include green and legal/regulatory as well as geo political factors.
We can consider supply chain to be strategic while logistics is more tactical. Global supply chain problems are complex and involve all of the above levels. Logistics problems can usually be managed within Levels 1 and 2.
Contact mitch@52.91.45.227 for immediate logistics support.
*Global Logistics & Supply Chain Management by John Mangan, Chandra Lalwani, Tim Butcher, and Roya Javadpour
Tony Rodriguez• President & Owner, Daniel Penn Associates.
Spare parts inventory control is no cakewalk. Read part two of a series by DPA’s Kenneth Staller and learn how to contain the chaos. Let us know your experiences.
Mitch Kostoulakos, LCB Licensed Customs Broker, International Logistics Consultant
Hi Tony, this article is very helpful. Several of my clients have added HTS (Harmonized Tariff Schedule) columns to their inventory lists as they are updated. This makes it easier to resolve customs delays in the supply chain.
Zoom meetings have mostly replaced face to face sales calls for LSP (Logistics Service Provider) representatives. This situation may be changing but, for now, I’m hearing a lot of frustration from former colleagues and clients. LSP reps are under pressure to conduct an aggressive number of zoom meetings or phone contacts per day. Activity becomes the main goal overshadowing value propositions. Indications are that this strategy will continue as it reduces costs and can increase call productivity.
Many clients are working remotely and with reduced staffing so understandably want to avoid these calls. The discussion usually includes small talk, commiseration, service issues, and client complaints about rates or surcharges. Let me suggest an alternative approach that can be an advantage for small/medium shippers. Rather than avoid the calls why not look to set the agenda and add your own value while also reducing the number of routine calls? I guarantee that you will have your LSP representative’s attention.
A common mistake made by small and medium sized clients is failing to prepare before meeting with LSP representatives. This leaves the agenda, and control, in the hands of the LSP rep. Another mistake is focusing immediately on price. Keep in mind that the lowest rate is not usually the best rate. A better strategy is to begin with value components in your discussions with providers. If you determine that they have the capabilities to provide quality services, then you can move the discussion to price.
Take a few minutes to list two or three agenda items prior to meetings with LSPs. These can include immediate issues as well as long term goals. State your agenda up front and see what happens!
ICS Global Services Limited477
Having the correct documentation is vital when importing or exporting, as inappropriate or overlooked documentation can lead to shipping delays, increased costs and business risks, such as cancelled international commercial activities.
Mitch Kostoulakos, LCB Licensed Customs Broker, International Logistics Consultant
It is a fact that most customs delays are caused by missing or inaccurate documentation.