What Is A Reexport ?

In several recent posts we discussed EEI filing, how to determine ECCN, and what is meant by EAR99. It is important to understand that Export Administration Regulations apply to reexports as well as exports. Here is the definition of reexports from the BIS (Bureau of Industry and Security) and a link to their publication Reexport Controls.

A reexport is the shipment or transmission of an item subject to the EAR from one foreign country (i.e., a country other than the United States)to another foreign country. A reexport also occurs when there is “release” of technology or software(source code) subject to the EAR in one foreign country to a national of another foreign country.

https://www.bis.doc.gov/index.php/documents/licensing-forms/4-guidelines-to-reexport-publications/file

Export best practices mean confirming that you are in compliance on all transactions. Don’t assume, validate!

Contact mitch@52.91.45.227 for assistance.

LinkedIn Comments

Dean Maciuba• 1stLast Mile Experts Large Parcel Rate Increases

If you follow me on LinkedIn, you have seen me opining on the parcel based, dynamic pricing environment enveloping the customers of FedEx and UPS. In more simple terms, the mega carriers are and will be taking selective rate increases on a regular basis.

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

Good reminder that a vibrant USPS is needed…

LinkedIn Comments

Gustavo Dobles•

1stOperations and Content Executive | Strategic Business and Operational Planning and Management | Process Improvements Asking the expert teams on the ground what should be done and what it will take (and you should…) is not enough: then be ready and willing to pay attention, consider carefully what is being conveyed, and make decisions accordingly.

Just as deficient or perhaps even worse than not asking, is ignoring the expert advise given.

The highest form of thinking is through the synthetic reconciliation of different and many times contradictory points of view.

Synthesis: the dialectic combination of thesis and antithesis into a higher stage of truth (Merriam-Webster Dictionary)

#leadershipcoaching#leadershipdevelopment#leadership#managementdevelopment#management#managementcoaching

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

Very good advice….Thanks Gustavo

Time for Some Spring Cleaning

Most managers or owners of small/medium companies wear many hats and usually do not have in-house logistics or compliance expertise. As a result, major projects such as implementing an Export Compliance Program become back burner issues. But doing nothing about compliance is not an option!

Let me suggest 3 spring cleaning best practices that will help you get started :

1) Scrub your parts list to make sure HTS or Schedule B codes are valid. The tariff changes periodically and we have found that every client parts list reviewed has included obsolete or invalid codes. Once identified these codes can be updated.

2) Check the CCL (Commerce Control List) to see if your commodities are listed. Exports must show the correct ECCN (Export Control Classification Number) in order to determine if a license is required. If you are automatically using EAR99 and NLR you are at risk of violation.

3) Set up procedures for checking common “Red Flags” such as denied parties lists, entities lists, and unverified lists. BIS (Bureau of Industry and Security) has up to date info on their website.

Ad Hoc Logistics can take complete these tasks or help you manage them.

Contact mitch@adhoclogisics.com

LinKedIn Comments

Glynn Lloyd• 2ndExecutive Director at The Foundation for Business Equity

I don’t understand why our corporate leaders are not willing to invest in the betterment of this country. It is time for those who get it to stand up. I, for one, as a small business owner support paying a little more taxes to support the infrastructure my business relies on, but more importantly to contribute my fair share to build an equitable and less extractive economy.

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

I agree and posted on this topic yesterday

Invest In Infrastructure

https://source.asce.org/asces-2021-report-card-marks-the-nations-infrastructure-progress/

The American Society of Civil Engineers has issued it’s 2021 Report Card for America’s Infrastructure. It is an interesting read. The overall grade is C- and trending up. No one in the transportation business will be surprised that Roads scored a D.

With C- being an upward trend it shows the poor condition of our infrastructure and how much work remains to be done. In fact, the overall score would be worse if not for B and B- for Rail and Ports.

I have traveled on roads in most EU countries and found them to be in much better shape than ours. The ASCE report notes that the upward trend in overall score can be attributed to increased investment to date. No doubt that, whatever our political views, we can agree that additional investment is urgently needed. Infrastructure won’t fix itself!

LinkedIn Comment

David J. DiSanto• DiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization4h • 

Good luck with increasing your private fleet….DG

The driver shortage, aggravated by the coronavirus pandemic, is reverberating throughout the trucking industry. The problem has reached the point where fleets are noting a shallower pool of independent drivers.
“The available pool of independent contractor drivers is smaller than it has been historically,” Truckload carrier Marten Transport stated in its annual report, filed March 1 with the Securities and Exchange Commission.

https://www.transportdive.com/news/dollar-general-logistics-private-truck-fleet/597183/?utm_source=Sailthru&utm_medium=email&utm_campaign=Issue:%202021-03-29%20Transport%20Dive%20%5Bissue:33271%5D&utm_term=Transport%20Dive

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

I agree with you Dave. I’m sure DG has done their due diligence. However, a private fleet is a risky move and just as likely to add costs rather than reduce them. A couple of big questions: Will drivers be company employees with full benefits? Will the fleet have access to back hauls or will there be significant deadheading?

Screen Yourself

I frequently conduct no fee discussions (phone or Zoom) with new clients to determine if I can help them. They may be unsure about their HTS codes or a specific regulation. Exporters quite often assure me that their commodities fall under EAR 99 and NLR (No License Required). While this may be true, due diligence requires verification which starts with checking ECCN (Export Control Classification Number). BIS (Bureau of Industry and Security) spells out the specific procedures for checking ECCN and licensing requirements. The CCL (Commerce Control List) Index is a good place to start.

https://bis.doc.gov/index.php/documents/regulations-docs/13-commerce-control-list-index/file

Here is some more info from the BIS website:

What does EAR99 mean?

If your item falls under U.S. Department of Commerce jurisdiction and is not listed on the CCL, it is designated as EAR99. EAR99 items generally consist of low-technology consumer goods and do not require a license in most situations. However, if your proposed export of an EAR99 item is to an embargoed country, to an end-user of concern, or in support of a prohibited end-use, you may be required to obtain a license.

Contact mitch@52.91.45.227 for assistance

LinkedIn Comments

#internationaltrade

Post from Ira Kawaller

https://igkawaller.medium.com/trade-policy-reconsidered-c7b1f780b86c

The transition to a new administration offers the opportunity to review federal priorities with respect to international trade policies. Reconsideration of our use of tariffs should be at the top of the list.

Mitch Kostoulakos, LCB  Licensed Customs Broker, International Logistics Consultant

Well said. This post clearly and concisely states the view that tariffs burden US consumers and businesses more than other parties. Using tariffs to punish or retaliate is poor trade policy.

International Logistics Consulting; Licensed Customs Brokers