Posted on LinkedIn:

A recent client project involved research and advice about Schedule B codes used in AES (Automated Export System) filings. Shippers often use Schedule B or Harmonized codes they have been given without understanding what the codes mean. 

 As I usually explain to clients, Schedule B is for export from the US and Harmonized codes are for imports. Both are based on the HTS system in which the first 6 digits are universal.

https://lnkd.in/eVc

Importing countries can ( and do) use their own last 4 or 6 digits.  So, since a US export is another country’s import, the Schedule B used for export may not match up exactly to the importing country’s harmonized code. 

As noted in a previous post, codes are updated annually so it is a good business practice to check and verify your data. If you need help contact mitch@52.91.45.227T

Posted on LinkedIn today

Here is a question from a recent Customs Broker exam. Take a guess. Non brokers please.

Importations of switchblade knives is permissible by 15 U.S.C 1244 if:

A. The importation is pursuant to a contract with a branch of the State Militia.

B. The importation is destined for a specific member or employee in a branch of the Armed Forces of the United States specifically for personal pleasure off-duty use.

C. The importation of the switchblade knives have a blade not exceeding 6 inches in length.

D. The entry will contain, among other documents, a declaration in duplicate stating that the switchblade knife has a blade not exceeding 3 inches in length and is possessed by and is being transported on the person of an individual who has only one arm.

E. The entry will contain, among other documents, a declaration in duplicate stating that the switchblade knife has a blade not exceeding 6 inches in length.

Chad Wegscheider on LinkedIn

Why are trucking companies failing? Why is it so hard finding a reliable carrier in today’s world?

Great question Chad and your points are valid. I don’t think loyalty is really a factor though. Trucking became a commodity starting with deregulation in the 1980s. Carriers compete on price and yet must provide better service as demanded by the market. Raising their rates risks losing market share. Labor costs are the biggest input so wages are kept down and there are very few unionized carriers remaining to negotiate. Advantage shippers. 

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 logistics 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 averages. 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 an upper mgt responsibility.

Need help? contact mitch@52.91.45.227

ECCN, CCL, NLR, EAR99, AES, HTS, SchedB, and these are just the basics…

When the ECCN (Export Control Classification Number) comes up on export documents many shippers automatically enter EAR 99. For license questions NLR (No License Required) is often used as a default entry. While these may be the correct entries, it is a good business practice to check and confirm.   Logistics providers can offer expertise in these areas but the exporter bears primary responsibility for compliance.

As part of any Export Management Program, exporters need to make sure they are using correct commodity classifications and license exceptions. Your commodities may be listed on the  CCL (Commerce Control List) in which case EAR 99 is not valid.  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.”

Licensing is a function of both the ECCN and country of ultimate destination. If you determine that your commodity is listed on the CCL the next step is checking license requirements. Here is some info from the BIS (Bureau of Industry and Security) website:

Country Guidance

The country of ultimate destination is a key factor in determining license requirements administered by the Bureau of Industry and Security (BIS) pursuant to the Export Administration Regulations (EAR). BIS maintains the Commerce Country Chart to use in conjunction with other portions of the EAR to determine whether a license is required.  Please review Part 732 of the EAR for additional information on how to use the EAR, including the Commerce Country Chart.

For immediate assistance with exports contact mitch@52.91.45.227 .

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As we discussed in a previous post, duty rates on imports are determined by harmonized code, valuation of the commodity, and country of origin. While trade agreements such as NAFTA have specific and complex rules of origin, the basic COO elements are:

Country in which the commodity is made, mined, grown, manufactured, or underwent substantial transformation. The 3 way test for substantial transformation is new name, new character, new use.

Need help? contact mitch@52.91.45.227

During our initial consultations clients often tell me that their shipping departments are responsible for screening exports for red flags and denied parties/unverified parties. This is a mistake for several reasons.

• Pressure to get shipments out the door can get in the way of due diligence
• Shipping personnel may lack training in export compliance
• Shippers most likely do not have authority to stop orders when they spot red flags
• Time and money wasted in processing orders all the way through to packing and shipping only to be stopped or cancelled
• In the event of a mistake there is no final check when the truck backs up to the dock

Export compliance, list screening, and checking for red flags should be a front end process and not a last minute shipping function. Let your shippers do what they do best by moving the freight but don’t expect them to be regulatory experts.

Need help? Contact mitch@52.91.45.227 for a no obligation initial consultation.

In a recent post we discussed the World Bank Logistics Performance Index (LPI) for 2018. Mexico ranks 51st overall with customs clearance as the lowest category. As Mexico is the US’s 3rd largest trading partner, this can cause delays and frustration for traders.
Here are some takeaways from  a US Commercial Service webinar that may be helpful in understanding the process.

Mexican Importer of Record (IOR)

• very rare for foreign company to be MX IOR
• MX IOR is always liable for duties/taxes and compliance with non tariff barriers
• MX brokers have significant liability, explaining their caution and due diligence which can become red tape and delays for the US exporter
• MX IOR must have tax registration number and be listed on importer registry

Classification and Valuation

• HTS code up to 6 digits same as other countries but subject to customs verification
• MX uses 8 digit codes so last 2 digits are unique to MX
• MX broker verifies or determines correct code and non tariff barriers
• Valuation determines duty/tax according to MX law based on WTO rules (TV- Transaction Value, etc)
• Non tariff barriers are regs not related to taxation such as trade agreements, anti dumping, etc
• Binding rulings can be requested for classification, valuation or NAFTA rules of origin

When Are Goods Seized?

• unauthorized port of entry used…mostly contraband
• failure to comply with non tariff barriers
• goods not declared on entry docs including errors
• false name/address of IOR or false invoice
• undervalued goods

Frequent Issues for MX Customs

• Origin verification for US and CA companies claiming NAFTA preference
• Failure of exporters  to respond to questionnaires from MX customs
• Exporters address different from address on NAFTA cert
• Exporters lack of knowledge about NAFTA rules of origin
• Lack of original records

MX Customs Recommendations

• Know your MX buyer and their customs broker
• It is OK to contact MX customs for info…they will reply in English
• Make sure NAFTA certificates of origin are accurate….many exporters simply guess
• Keep original copies of documents….MX customs will only verify using original docs
• Make sure to respond to questionnaires or requests from MX customs within 30 days
• Communicate before goods are seized or litigation begins…best to use a MX attorney
• Remember, prior notification to avoid liabilities does not exist in MX as it does in US

Posted on LinkedIn

Surprised? Check out these logistics rankings… The World Bank has posted their Logistics Performance Index for 2018. The index benchmarks 6 areas of performance and gives nations a score from 1-5 for each area.

The benchmarks are 1) Efficiency of customs clearance process, 2) Quality of trade related infrastructure, 3) Ease of arranging competitive pricing for shipments, 4) Competence and quality of logistics services, 5) Ability to track and trace shipments, and 6) Timeliness of shipments in reaching destination within scheduled time of arrival.

For 2018 the US ranks 14th overall, down from 10th in 2016, with an average score of 3.89 for the 6 benchmarks. The highest US score is 4.09 for tracking and tracing, and the lowest is 3.51 for ease of arranging international shipments. This may be due to the wide variety of services available to US traders which can make comparisons more complex.

Germany ranks highest in overall LPI rank.

https://lnkd.in/dh7Srey

Around The World

lpi.worldbank.org

Welcome to the 2018 LPI The LPI is an interactive benchmarking tool created to help countries identi…

4 Tips to Improve Carrier Relationships

• Published on May 23, 2019

Anthony (Tony) Nuzio

Founder/CEO ICC Logistics Services

Status is online

Mitch Kostoulakos, LCB   YouLicensed Customs Broker, International Logistics Consultant

Hi Tony, these are good tips. I would add share your shipping profile (volume, frequencies, lanes, freight characteristics) with prospective carriers. Holding back this info won’t get you a better deal.