LinkedIn Comment

David J. DiSanto • 1stDiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization2w • 2 weeks agoWould you buy airline stock now ?400,000 Jobs Lost at Airlines During Coronavirus Pandemicaviationpros.com • 2 min readAbout 400,000 airline workers have been fired, furloughed or told they may lose their jobs due to the coronavirus, according to Bloomberg calculations. The aviation industry has suffered more than most as the pandemic destroys ticket sales and strips..

Mitch Kostoulakos, LCB 

1m

Good question Dave. Would be a great investment if you pick the right airline.Like Mitch Kostoulakos, LCB’S comment

BIS Webinar

The Bureau of Industry and Security is a good resource for export compliance information and training.

Complying with U.S. Export Controls Virtual Seminar September 9-10, 2020

September 9-10, 2020 Complying with U.S. Export Controls

This two-day virtual program is led by BIS’s professional counseling staff and provides an in-depth examination of the Export Administration Regulations (EAR). The program will cover the information exporters need to know to comply with U.S. export control requirements on commercial goods. We will focus on what items and activities are subject to the EAR; how to determine your export control classification number (ECCN); steps to take to determine the export licensing requirements for your item; when you can export or reexport without applying for a license; export clearance procedures; and record keeping requirements.

A Little Due Diligence

As I have written in previous posts, it is a mistake to leave export compliance in the hands of your shipping department. Shippers are under time pressure to get shipments out the door and often do not have sufficient knowledge or training to avoid mistakes. In addition shippers rarely have the authority to stop shipments if they spot red flags and this can have big consequences. So don’t give shippers the responsibility for compliance without the authority.

Many exporters automatically classify their shipments as EAR99 and NLR without checking that these designations are accurate. A little due diligence goes a long way so here goes.

Exporters, do you know how to determine your ECCN (Export Control Classification Number)? While it is true that many exported commodities can be designated EAR 99 and NLR (No License Required), it is important to first check for an ECCN. The correct ECCN is necessary in order to determine if a license is required for your shipments.

There are three ways to determine ECCN: 1) self classify, 2) consult manufacturers of commodities, 3) request a classification by BIS.

The CCL (Commerce Control List) Index @ bis.gov is a good place to start.

https://lnkd.in/gi4iFCu

If you need help contact mitch@52.91.45.227

Test Yourself

In a recent post we discussed Country of Origin and “substantial transformation”. Here are a few questions from the April 2019 Customs Broker License exam. If you sit for the exam you have 4.5 hours to answer 80 questions, or a little more than 3 minutes per question, in an open book format. Questions 8 and 9 may seem obvious using the substantial transformation rule. Question # 11 will take a deeper dive into the regulations and this is what makes the exam difficult as it may consume valuable time. Test yourself and post your answers if you like.

8. Swedish iron ore is refined into steel near the town of Essen, Germany, and subsequently fashioned into automobile radiators in Bratislava, Slovakia, in 2018. What marking is required for the automobile radiators?

A. Product of EEC B. Made in SK C. Product of Germany D. Made in Slovakia E. Made in Czechoslovakia

9. Fish are caught by a Norwegian flagged vessel in international waters off the coast of Portugal. The fish are kept either whole or filleted on-board. The fillets are sent to England, where they are seasoned, battered, and pre-fried. What is the country of origin of the battered fillets?

A. Portugal B. England C. Norway D. Canada E. Spain

11. Mr. Smith contacts your brokerage from the Customs area at the local international airport. He has just flown in from the UK and is attempting to bring in new Scottish 100% wool sweaters to sell at his new store. CBP has advised him that although an appropriate country of origin label is found affixed to the sweaters, the fiber content label is not acceptable. Which of the following actions should the local CBP brokerage take? A. The sweaters should be released to Mr. Smith if he agrees to remove the content label because no labeling is needed due to the exemption of wool wearing apparel. B. The sweaters should be released to Mr. Smith because they fall under the Wool Products Labeling Act of 1939. C. The sweaters must be returned to the UK. D. The sweaters should be released to Mr. Smith, but he will have to label the sweaters at his own expense under Customs supervision. E. The sweaters should be released to Mr. Smith, but a marking duty equal to 10% of the price in the domestic retail market duty should be assessed against Mr. Smith.

A. The sweaters should be released to Mr. Smith if he agrees to remove the content label because no labeling is needed due to the exemption of wool wearing apparel. B. The sweaters should be released to Mr. Smith because they fall under the Wool Products Labeling Act of 1939. C. The sweaters must be returned to the UK. D. The sweaters should be released to Mr. Smith, but he will have to label the sweaters at his own expense under Customs supervision. E. The sweaters should be released to Mr. Smith, but a marking duty equal to 10% of the price in the domestic retail market duty should be assessed against Mr. Smith.

Mid Year HTS Revisions


The United States International Trade Commission has updated the Harmonized Tariff Schedule of the United States effective July 1, 2020. Mid year is a good time to review your harmonized codes. The change record for this revision includes 4 pages of newly established, modified, and discontinued codes.

Using obsolete codes can result in customs delays, inaccurate  duty assessments, or fines and penalties so it is a good business practice to check the tariff. While you are at it are you sure EAR99 and NLR apply to your exports?

For assistance contact mitch@52.91.45.227

Comment on LinkedIn

Mitch Kostoulakos, LCB commented on thisDavid J. DiSanto • 1stDiSanto & Associates, Inc. Consulting in Supply Chain Analysis & Optimization2w •

The airline said it’s starting to see signs people are flying again. United expects passenger revenues to grow 50% to 100% between June and July, though that will still be down as much as 88% compared with last July, normally part of the busy summer travel season.

United Taps Frequent Flyer Program for $5 Billion Loan as Air Travel Remains Sluggish….United Airlines is using its frequent flyer program to borrow $5 billion as passenger travel, which ground to a near-halt during the COVID-19 pandemic, starts to pick up but remains far short of a typical summer travel season. The loan secured by its…

Mitch Kostoulakos, LCB   Licensed Customs Broker, International Logistics Consultant

EU is not an option for Americans right now

Measure Absolutely

The economic downturn we are experiencing will no doubt result in some consolidation in the Logistics Service Provider (LSP) industry. For clients who are planning to change providers this is a good time to establish service standards that are relevant to their operations. For example, on time service standards are basic and common to all LSPs .

Most logistics service providers present clients with monthly reports touting their on time delivery percentage. It is easy to become complacent when LSPs routinely report 97-99% on time service after taking exceptions for weather and other factors.

Why not challenge them to measure absolute performance failures instead of percentages? In a high volume operation even a small percentage can mean a lot of late shipments and unhappy customers. In a smaller operation with fewer customers every shipment is critical. If LSPs can track and report percentages they should be able to do the same for absolute numbers of shipments. FedEx has measured absolute performance for years.

Finally, if you are an LSP, remember that you have a client on both ends of the shipment, so service failures have twice the impact. Different metrics are like fresh eyes on an operation.

Need help? Contact mitch@52.91.45.227

Mitch’s LinkedIn Comments

Liz Ryan • 3rd+Founder and CEO, Human Workplace; Author, “Reinvention Roadmap”

“Fake fun” at work has nothing in common with real job satisfaction. “Fake fun” is insulting and annoying. One of the worst things HR people, CEOs or anyone else can do is to pretend that “fake fun” will make your workplace a great place to work.

I don’t need a foosball table or free beer on Friday nights – I need

RESPECT
FAIR PAY
CLEAR DIRECTION
THE RIGHT EQUIPMENT AND TOOLS
APPROPRIATE TRAINING FOR MY JOB
RESPECT FOR MY PERSONAL TIME
THE LATITUDE TO DO MY JOB
TO BE ABLE TO SHARE MY OPINION WITHOUT WORRYING THAT DOING SO WILL HURT ME
S

Mitch Kostoulakos, LCB   YouLicensed Customs Broker, International Logistics Consultant

Excellent Post Liz. HR departments spend a lot of time and money trying to “motivate” thru games, cheerleading, and lucite awards. I have taught performance management seminars featuring the points on your list. These are the true motivators.

Importing and Country of Origin

When updating clients’ inventory and parts lists questions about country of origin come up regularly. Country of origin, often abbreviated COO, is one of the elements, along with harmonized code and commodity valuation, in determining duty/tax rates. While trade agreements such as NAFTA (now USMCA) 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.

Substantial Transformation Rule….used to determine country of origin if articles or components are not wholly obtained from one country…Does article have new name, character, or use?

  • Change in character- altered physical characteristics of article or components. Were changes cosmetic? What was the process that resulted in change?
  • Change in use- Is end use of article interchangeable with end use of components? Is end use of component predetermined at time of importation? What was the process that resulted in change of use? Predetermined end use generally precludes substantial transformation but subject to specifics of article/components in question.
  • Change in name- this is the least compelling of the factors supporting substantial transformation. Do components retain original name after processing?
  • Subsidiary/Additional Factors- extent and nature of operations (complex or simple); value added and/or cost incurred during transformation process; essential character of article (components transformed into finished product); change from producer to consumer good; tariff shift.

Ad Hoc Logistics can help with regulatory questions or your international logistics needs. Contact mitch@52.91.45.227

International Logistics Consulting; Licensed Customs Brokers