This afternoon I participated in a webinar presented by Customs Info/Descartes on “Best Practices in Global Classification Compliance”. The first half of the webinar consisted of a good refresher about classification compliance. The Customs Modification Act requirement of reasonable care was defined as a solid process of research support and documentation. The presenter reminded the audience that:

• Classification is subjective- tariff schedules do not necessarily keep up with technology
• Customs definitions can differ from industry definitions
• Different interpretations exist between countries and also between ports within the same country

The basic components of a best in class process are:

1. Break down items from universe into groups
2. Research- even if you think you know the correct classification    customsinfo.com is a good tool
3. Identify necessary info needed for classification such as materials, dimensions, intended use, etc
4. Documentation- needed to support your determination
5. Automation- implementing a software classification tool will improve efficiency and productivity
6. On-going maintenance and monitoring for changes in HTS binding rulings and in your products is essential

Supporting documentation includes

• spec sheets, drawings, photos
• info requests from engineers, scientists, chemists, etc
• HTS chapter and section notes that apply to your product
• explanatory notes
• informed compliance publications
• customs rulings that apply to your product
• record keeping (5 years)

Contact Ad Hoc Logistics for help with classification and compliance.

Many exporters automatically enter EAR 99 on their shipping documents without really knowing what this designation means. EAR 99 is a basket category for items that are subject to the EAR (Export Administration Regulations) but not on the CCL (Commerce Control List).  The CCL lists “controlled” items which may require a license for export. The CCL is made up of a classification of items by ECCN (Export Control Classification Number).  So a basic export compliance step is to verify if your items are “controlled” needing an ECCN or if they can be shipped under EAR 99. If an ECCN is listed you then need to determine if a license is required by checking “Reasons for Control” and destination country lists. There are 3 ways to determine an ECCN:

1) Check with the manufacturer, producer, or developer.

2) Self classify using the CCL.

3) Official request to BIS (Bureau of Industry and Security) using the SNAP-R tool @ bis.gov

Contact adhoclogistics.com for help in determining your ECCN.