I am honored to accept appointment to this committee.

Dear Mr. Mitch Kostoulakos,

On behalf of the Transportation Research Board (TRB), I am pleased to offer you the following appointment:

Member, Main Member Slot — Standing Committee on International Trade and Transportation — AT020

NOTE: The name and code of this committee may be subject to change due to the committee restructuring scheduled to go into effect after April 15th.

Term – April 15, 2020 – April 14, 2023

TRB is one of seven program units of the National Academies of Sciences, Engineering, and Medicine, which provides independent, objective analysis and advice to the nation and conducts other activities to solve complex problems and inform public policy decisions. Members of the National Academies’ technical committees serve as individuals, not as representatives of the organizations by which they are employed or of which they may be members. Through their appointment, members agree to actively participate in and support the committee’s activities, including those that will require volunteer work. More information about the roles and responsibilities of committee membership is available at http://onlinepubs.trb.org/onlinepubs/dva/memberguide.pdf

The current business environment has a post 9/11 feel to it. LSP account executives are off the road along with everyone else. Operations and customer service are disrupted. I am hearing the frustration from providers and their clients. The challenge for account execs is to maintain their account base and assist with operations and service issues without face to face contact.

This is not the time for sales pitches or cold calling. Clients are likely working from home and would not welcome this approach. Accounts execs can add value by problem solving and customer service support if clients will give them the opportunity.

My suggestions are for acct execs to hold off on the sales pitch for now and build the relationship through service. For clients, you would be smart to take the LSP rep’s phone calls and let them help you. Remember, they are trying to do their job and you can always cut the call short if it turns into a sales pitch.

Customs Brokers

UPDATE  Due to the unprecedented situation related to coronavirus (COVID-19) across the country, and the closure of our testing centers, Customs and Border Protection (CBP) regretfully must postpone the April 1, 2020 Customs Broker License Exam (CBLE).   CBP will provide additional information in the coming days, so please check cbp.gov website for updates.   For immediate concerns regarding the broker exam, you may email Broker Management Branch at brokermanagement@cbp.dhs.gov

Heather Noggle • 2ndExport Compliance Data Expert | Master Data Integration Consultant | CEO Exits, Inc. | Helping Companies Manage Data4d • 4 days agoI’ve been working with a remote team for the last 14 years. We serve customers everywhere without a central location. Tips for the new home-based workers: 1) A regular meal in the middle of the day with the other humans around you does wonders. 2) Laundry and other small chores are great for brain processing. Do not feel guilty doing symbiotic chores/thinking. 3) You’ll need to remind yourself to move more often. 4) It’s very easy to lose track of time. You’re more productive at home – typically – and the movements and conversations of others aren’t present and cueing some of your own social behaviors. 5) This one’s new – stop reading about the Coronavirus every hour. I think this one I am directing at myself. Cheers to all. hashtag#remoteworkhashtag#remoteculture…

Mitch Kostoulakos, LCB   Licensed Customs Broker, International Logistics Consultant

Agree….I have been working remotely for a number of years. What may come as a surprise is how much more productive you can be! Mitch Kostoulakos, LCB’S comment

When business slows down Logistics Service Providers (LSPs) must adjust staffing to match reduced volume and this presents challenges to their clients. Trusted LSPs and 3PLs are valuable resources for any business. They are the arteries through which supply chains function. Hopefully staffing cuts are temporary but, for now, they do add risk for clients.

Exporters, not LSPs, bear primary responsibility for compliance with regulations. In reality, though, many exporters rely on their freight forwarders to manage compliance for them. This has always been a mistake but even more so when the LSP reduces staffing. Documentation errors, misclassification, and failure to check licensing requirements are examples of the risk for exporters. Best practices in this area would be to review all documentation produced by LSPs, check shipments for “red flags”, and consider establishing a formal Export Compliance Program for the future. Here are some previous blog posts for reference:

Manage the Risk, 1/15/2020

How to Determine ECCN, 12/6/2019

Compliance Nuts and Bolts, 11/30/2019

Reviewed Your CI Lately? 11/3/2019

Red Flags, 9/29/2019 and 10/6/2019

Basic service levels are also impacted by LSP staffing cuts. Pick up and delivery routes will be combined so drivers are covering wider zones. This can mean late deliveries, missed pick ups, or late pick ups requiring overtime for the client. Remaining clerical staff may struggle to field customer service requests on a timely basis. Best practices here include gaining a comfort level with your providers’ on-line resources and developing problem solving protocols to save time. Blog posts for reference are:

Manage Your Carrier Relationships, 8/8/2019

Got Protocols? 4/6/2019

Need Help? contact mitch@52.91.45.227

Pete Mento • 2ndManaging Director Global Customs and Duties, Crowe LLP1d • Edited • 1 day agoYou can freak out a little about this: Everyone – and I mean EVERYONE engaged in cross border trade needs to do two things right now – learn everything they can about “Force Majeure” clauses AND start combing through all of their contracts to see where they are and how they will be impacted by them. Because that term is about to get swung around like a bottle of Jager at a bachelor party. Like Hunter Thompson always said – “When the going gets weird, the weird turn pro….” hS

Mitch’s Comment

good reminder to check the boilerplate

Many of my clients are hard-working owners or operators of small businesses. They don’t have in-house compliance or logistics expertise so must wear several hats. Day to day activities or unexpected issues take up most working hours. As a result, functions such as logistics planning and import/export compliance are often unmanaged.

Making sure that your business is in compliance with import and export regulations is good risk management as well as good business. Think of it as insurance. I have written about compliance as risk management in previous blog posts. Here are a few:

• Manage the Risk, 01/15/2020
• Start off 2020 With a Customs Review, 01/09/2020
• Compliance Nuts and Bolts, 11/30/2019
• Red Flags, 09/29 and 10/06/2019
• Let Shippers Ship, 06/13/2019

Logistics consists of equal parts planning, execution, problem solving, review/adjust, rinse and repeat. If you find yourself spending a lot of time problem solving then planning and/or execution need to be improved. Trusted LSPs (Logistics Service Providers) and 3PLs are valuable resources. At the very least, however, they need to be managed through monthly or quarterly review meetings for which you set the agenda. Here are a few more blog posts for reference:

• Negotiate Value Before Price, 09/10/2019
• Managing Carrier Relationships, 08/08/2019
• Got Protocols? 04/16/2019

Don’t be an unmanager!

For help contact mitch@52.91.45.227

Posted on LinkedIn

Are you taking the Customs Broker exam in April? If you are planning to take the customs brokers exam in April you should be well into your preparations by now. Passing rates are usually in the single digits so the exam is not easy. However, a step by step study plan will give you confidence. I devised a simple method that worked well for me. Read the attached post for details and best of luck.

I’m always amazed when clients tell me that they leave export compliance in the hands of their shipping department.

If you are relying on your busy shipping department or your logistics service provider 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.

contact mitch@52.91.45.227 for assistance.

An annual customs review is a good business practice. Another good practice is to make sure you are taking advantage of regulations that allow importing on a duty free or preferential basis. Here are a few basic items for your annual customs review. Contact mitch@52.91.45.227 if you need help.

• Classification– review annual updates to Harmonized Tariff to make sure your codes and descriptions are accurate. Proper classification and valuation of imported goods are the first step in compliance. If you do nothing else, do this.
• Duty Drawback– this is a refund of duties paid on imports that are later exported. As supply chains expand there may be new opportunities for drawback. Record keeping is key here.
• Chapter 98 of the Harmonized Tariff allows duty free entry of certain categories of goods. Examples are: American Goods Returned, American Goods Repaired or Altered Abroad, and American Components Assembled Abroad.
• Trade agreements– programs which allow duty free or reduced duty rate entries. There are many agreements (such as NAFTA) in place.
• Customs rulings– consider requesting formal customs rulings prior to large transactions. This ensures compliance and eliminates uncertainty about imports. Rulings can be requested thru the CBP website.
• Correcting errors– when an entry mistake is discovered it can be corrected by a prior disclosure to CBP. The formal process is a Post-Entry Amendment/Post Summary Correction. A prior disclosure can help mitigate penalties.