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April, 2011

Be ready for CBP’s security update to ACE Secure Data Portal

Tuesday, April 26th, 2011

Pursuant to US Customs’ CSMS# 11-000088 – ACE TSL Implementation, CBP is making a security update to the ACE Secure Data Portal this week.

Customs is discontinuing the use of the SSL protocol while maintaining the use of the TSL protocol, and advises that ACE users ensure that their browsers are TSL compliant.  Changing your browser settings is very easy, and illustrated step-by-step instructions can be found here.

CBP strongly recommends that users effect this change by April 28th to avoid interruption of service. If you have any problem connecting to ACE on April 29th, double-check the browser settings to ensure they meet the TSL requirement.

CBP’s official notification is here.

Japan disaster aftermath: continued trade disruptions

Monday, April 25th, 2011

Japan’s triple disasters in March — earthquake, tsunami and crippled nuclear reactors — and the resultant electricity shortages have hit Japan’s economy hard and continue to disrupt manufacturing and supply chains worldwide, prompting Japan’s government to address this issue directly with global trade groups.

According to the International Business Times, about 60 countries and regions, fearful of radiation contamination, have imposed import restrictions on Japanese products.  Addressing these concerns, the Japanese government will be going into full PR mode with visits to importers and shipping agents around the world — including those in the United States.  The purpose of the trip is to “‘disseminate correct information’” about the effect of the nuclear plant crisis on Japanese exports of agricultural and industrial products.

The three disasters in the world’s third largest economy have seriously curtailed industrial production, resulting in a decline of exports in March, about 2.2% less than a year ago.  As reported in The New York Times, although Japan is still running a trade surplus, analysts predict that its economy may not begin to rebound until later in 2011 when reconstruction spending hits and manufacturing levels and electricity supplies increase back to pre-quake levels.  Nevertheless, “pain and uncertainty remain intense, particularly in the automobile and electronics industries.”

This pain contiues to be very real for US importers.  As noted in The Journal of Commerce, Johnson Controls, the Wisconsin-based maker of automobile batteries and interior systems, anticipates a half billion dollar hit on 3rd quarter revenues, due to manufacturing interruptions in Japan.

Unable to attend CBP’s Trade Symposium? Get presentations easily

Wednesday, April 13th, 2011

US Customs’ annual two-day 2011 Trade Symposium, “Working Together to Strengthen Economic Competitiveness,” kicks off today in Washington, DC.  If you cannot be there in person, or attend the live webcast, you can still obtain copies of all presentations in PDF format.  Visit CBP’s Trade Symposium 2011 Presentations page, and download as many presentations as you wish.  As of the time of this posting, there are over 20 PDFs available, with more to follow.


Supply chain disruption contingency planning – do it now

Monday, April 11th, 2011

The recent disasters in Japan, as well as other global crises in the last decade, have demonstrated an unfortunate side effect of the interconnectedness of global supply chains.  While suppliers in the affected regions clearly may have difficulty meeting demand, other vendors in your supply chain — located far from the disasters — may be similarly affected if they rely on receiving components from those regions.

SupplyChainBrain‘s Robert J. Bowman, in his blog post “Another Disaster, Another Supply-Chain Disruption.  Will We Ever Learn?”, notes that fewer than 10% of companies have adopted contingency plans to address this issue.

Bowman offers some recommendations:

  • Know who is supplying your Tier 1 suppliers, and distribute your global supply chain base accordingly.
  • Diversify your supply chain base by using an alternate vendor on a regular basis, so you can be up and running with them if a disaster adversely impacts your Tier 1 supplier
  • Develop a detailed contingency plan, assigning specific roles to your supply chain employees, and providing them in advance with the tools they need to implement the plan.

The full blog post is available here.

FDA guidance to expedite import entry review for medical devices

Monday, April 4th, 2011

On March 24, the US Food and Drug Administration (FDA) issued a guidance letter to importers of medical devices, electronic product components, parts and finished product into the US.

The recommendations are intended to expedite the import entry review process.  Generally, when a shipment of regulated medical devices enters a US port, US Customs passes any entry information received from the importer to FDA to ensure the products in the shipment meets FDA requirements.  If the data provided to FDA is accurate and complete, it is more likely that the shipment will be processed based on import screening and not held for further FDA entry review.  Otherwise, FDA will undertake a manual review of each line of your entry — which will delay the shipment’s release.

FDA recommends that the following information be submitted on the CBP entry paperwork:

  • consistent and accurate identifiers for firms
  • correct product codes for the product being imported
  • Affirmations of Compliance (AofC) codes along with their appropriate qualifier

With respect to the latter, FDA has developed new AofC codes and revised old AofC codes for use when completing customs entries for imported medical devices, which are outlined in an appendix to the March 24 letter.

Importers should ensure that their import personnel – brokers, filers, in-house compliance staff — are well versed with these requirements.

Finally, FDA indicated that it will issue a second letter pertaining to the import entry filing process for products subject to both the medical device and electronic product radiation regulations.

The March 24 letter is available here.