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February, 2012

e-Manifest: Trucks — updated user guide

Friday, February 24th, 2012

US Customs has just issued a newly updated user guide for e-Manifest:  Trucks, a capability that enables carriers to submit electronic truck manifests to CBP prior to a truck’s arrival at a US land border crossing.  The program offers the trade increased efficiency by saving valuable time at the border, reducing processing time, and offering online status tracking of trips.

The updated user guide now provides step-by-step instructions on how to create and submit an electronic manifest.  Other topics in the guide include:

  • Adding drivers, shippers, equipment to an account
  • In-bond shipment information
  • Creating unassociated shipments
  • And much more

The user guide is available here.

CustomsNow to present “Import Basic Operations” for MGTA

Tuesday, February 14th, 2012

Nic Adams and Randy Green, two executives with CustomsNow, will present an all-day seminar, “Import Basic Operations,” for the Midwest Global Trade Association on February 16.

This seminar will provide a basic overview of import operations including: requirements for documentation, compliance, recordkeeping, customs brokerage and classification/valuation.

The event will be held at King Solutions in Dayton, MN.

For more information, and to register, please click here.

What’s in store for ACE in 2012?

Monday, February 13th, 2012

US Customs continues to make good on its promise to focus resources on ACE improvements.  According to the ACE Trade Account Owner January 2012 update, here’s what’s in store for this year:

e-Manifest:  Rail and Sea (M1)

  • M1 pilot is underway, with full implementation expected in March
  • Rail and sea manifest processing in AMS expected to cease in September

Simplified Entry

  • Testing to begin in late January and pilot to launch in March

Document Image System

  • EPA and Marine Fisheries Service will join in CBP pilot test later this year

Participating Government Agency (PGA) Message Set

  • Full integration with Trade and other system components should occur as part of cargo release
  • Scheduled to be integrated with Simplified Entry Initiative later this year

Exports

  • In early 2012, CBP will kick off requirements gathering process

CBP issues updated bonded warehouse manual

Friday, February 10th, 2012

On February 6, US Customs published an updated version of its Bonded Warehouse Manual for Customs and Border Patrol Officers and Bonded Warehouse Proprietors.

The document, last updated in 1990, provides guidance to all interested parties with a stake in bonded warehouses.  Unfortunately, Customs has not yet provided guidance on which provisions have changed in the manual, which is nearly 200 pages long.

The complete manual is available here.

Seminar on Korea, Panama, Columbia Free Trade Agreements

Monday, February 6th, 2012

The Orange County (CA) branch of the Women In Trade organization is hosting a seminar and roundtable on February 9th on the US-Columbia, -Panama and -Korea trade promotion agreements which were signed into law on October 3,2011.  Although these agreements were scheduled to go into effect on January 1, 2012, they have not yet been phased in.

The event, which will be moderated by Maryavis Bokal, a Senior International Trade Specialist at the US Deparment of Commerce, will discuss the highlights of these new agreements, and to answer the question of what does it mean for American businesses?

For more details, and to register, click here.


ACE – New report to see late ISF filings

Friday, February 3rd, 2012

US Customs has announced that a new ISF Report is available in ACE for importers and filers to monitor whether any of their own filings are late.  Note:  Although the report is available in ACE, it tracks ISFs filed in both ACE and ACS.

Users will need to subscribe to the “Late ISF Importer Report (PDF).”   Use the steps below to subscribe to the new report:

  1. After logging onto the ACE Secure Data Portal, select the References Tab.
  2. Select Launch ISF.
  3. Select Reports.
  4. Select Subscribe to Reports.
  5. Select the Late ISF Importer Report (PDF).

Filers are reminded that the “By Filer By Importer Report” is available in both a PDF and an Excel format.

CBP’s official notice is available here.

Staffing an import compliance department

Wednesday, February 1st, 2012

A recent discussion thread on the Global Trade Compliance Professionals LinkedIn group page examined the issue of how many employees constituted a “properly staffed import compliance department.”   While there is of course no definitive answer that applies to all importers, the thread highlighted key considerations when evaluating staffing decisions, summarized below.

As pointed out by the discussions, the most obvious factors to consider in staffing levels are:

  • Import volume – entries and ISFs
  • Degree of complexity of entries
  • Average line items per entry
  • Number of ports/shipping lanes used
  • Involvement of OGAs
  • Degree of system automation

Additionally, the staffing number will also depend on whether the importer uses the services of a customs broker or self-files entries/ISFs.

  • If using a broker, the compliance staff must determine the level of involvement needed to provide the broker with all of the relevant information, to be available for follow-up questions and other oversight, and, most important, to audit the broker’s performance.
  • If self-filing, the importer must have resources dedicated to filing, including self-auditing.  In many cases, the number of employees necessary for direct filing may be the same or even less than that are required to oversee a broker, since the importer is more familiar with the particulars of their import stream, and it is more efficient to not use external parties.

In addition to entries/ ISFs, the staffing number will be affected by other responsibilities that the compliance staff will undertake, such as maintaining a compliance manual, employee training, product classification, filing PEAs, lodging protests, performing reconciliations, etc.

Beyond the specific number of import compliance personnel, another issue for an importer to consider is the type of positions that need to be created.   For example, the compliance department could need a supervisor, entry specialists, pre-entry specialists, and/or post-entry audit staff.

Moreover, there is some debate as to whether an importer needs a licensed customs broker on staff.  On the positive side, an LCB generally has more knowledge of the regulations than those who did not go through the licensing process.  Also, US Customs may view having an LCB on staff as a sign of the importer’s commitment to exercising “reasonable care.”  On the other hand, LCBs usually require a significantly higher salary, which may not be justified if there are other non-licensed experienced staffers who have a similar command of the regulations.

An import compliance department may augment its staff by “borrowing” from other departments.  For example, one respondent described her company’s situation:

…[O]ur shipping department contributes to our “Trade Compliance” program without being in our [international trade compliance] department….  Shipping interfaces with the shipping company and our homeland warehousing, while my department does the work with our Customs Broker, US Customs and our factory and manufacturing vendors for our scheduling, pricing/costs, problems, classifications, regulatory reporting ad the C-TPAT program….  I also draw from the Accounting Department for 1 or 2 people when needed for tasks that impact financial aspects…. These “borrowed” staffers are trained by us and frankly enjoy the change of scenery from their usual jobs.  All these instances of “sharing” personnel from different department help control our costs and department size.

And, of course, an import department may augment its staff by outsourcing certain functions to outside attorney, accountants, consultants and the like.

The Global Trade Compliance Professionals LinkedIn group page is available here (membership required).