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July, 2012

Save the date — CBP East Coast Trade Symposium

Tuesday, July 31st, 2012

US Customs has announced that its East Coast Trade Symposium will be held on September 27 and 28 in the Washington, DC area.  Additional information and registration options will be available soon.  Check here for more information.

If the event is as popular as this past spring’s West Coast Trade Symposium, we recommend that you register as soon as possible.  For those not able to attend, there will be an opportunity to subscribe to a live webcast of the event.

Trade Transformation – the big picture

Wednesday, July 25th, 2012

In the trade, there is much buzz about US Customs’ ongoing Trade Transformation efforts, by which the agency seeks to facilitate and secure US imports and exports by:

  • Driving down transactions costs to the trade
  • Creating efficiencies that result in expedited clearance and review processes; and
  • Aligning security and trade targeting and enforcement efforts around an “all-threats” agenda.

Many of the initiatives that comprise Trade Transformation, such as ACE improvements, Simplified Entry, and Centers of Excellence and Expertise, have been reported on extensively in this blog and elsewhere.  But for those who like to look at the “big picture,” US Customs, in its July 2012 CBP Trade Newsletter (page 8), provides the following graphic (reprinted below) that shows these initiatives in the context of the trade timeline.

Made in China…and Mexico, New Zealand, Israel, Korea, Taiwan…

Monday, July 16th, 2012

In the July 2012 print edition of American Shipper magazine, Associate Editor Eric Johnson provides a compelling example of the complicated nature of global supply chains….

It takes a globe

The Dremel is a pretty useful hand-held rotary tool available typically at your local hardware store.

It turns out it’s also pretty useful for describing just how ridiculously global supply chains have become.

Dremel is a company founded in Racine, Wis., and now part of Germany’s Bosch Tool Corp.

Looking at the box of a new Dremel, purchased by a friend, I was gob-smacked at the array of locations from which the product was sourced.  I quickly snapped a photo of the list for posterity.

Here it is:  “Tool assembled in Mexico.  Battery made in Malaysia.  Charger made in China.  Storage Case made in Mexico.  Accessories and attachment made in Canada, China, Germany, Israel, Italy, Korea, Mexico, New Zealand, Switzerland, Taiwan, or U.S.A.”

Keep in mind the entire box (including the tool and its accessories) is probably one foot by eight inches.  If that doesn’t underscore how complex international freight movement is, I don’t know what does.

Retailers hopeful for stronger peak season

Thursday, July 12th, 2012

Despite current global economic woes, the National Retail Federation is cautiously optimistic that imports to the US will increase during this year’s peak season.  According to Logistics Management, NRF expects consumer confidence to drive the increase, although it hedged its bet, indicating that consumer “spend during the next few months depends on what happens with employment.”

NRF made it projections in its recent Port Tracker report, which includes a survey of major ports such as LA/Long Beach, Seattle, and Miami.   The organization is hopeful that conditions will improve over 2011, which left some ports wondering if a peak season ever materialized.

For retail, peak season generally runs from June through the fall, encompassing the back-to-school through holiday timeframe.

The Logistics Management article can be found here.

Too many Post-Entry Amendments (PEAs)?

Monday, July 2nd, 2012
Some US importers are concerned that if they file “too many” PEAs, they will draw increased scrutiny of CBP, and may be setting themselves up for an audit.  Though that may be the case, importers can and should take steps to minimize, regardless.  Obviously, in order to reduce the number of PEAs filed, it behooves the importer to minimize data errors before the entry summary is filed.  To that end, following are a few suggestions:

  • Have a written procedure manual in place that outlines the responsibilities of internal staff and broker(s) for reviewing entries and supporting documentation prior to submission.
  • Involve and have written agreements in place with vendors, suppliers, forwarders, etc. that specify steps to be taken to ensure data accuracy.
  • Mandate training for all involved parties if the same errors persist.
  • Automate the audit process.  For example, request that your broker send you a file representing the entry details and systematically validate the HTS, value, etc.
  • If most of your errors are for one issue (e.g., HTS), consider flagging the entries for reconciliation.

An inordinate number of PEAs may trigger increased CBP scrutiny, specifically by the Import Specialist(s) in the port(s) where submitted.  If this is a concern, make sure to communicate to the IS the reason for the influx, and the specific plans in place to minimize errors going forward.

As many know, the PEA process is cumbersome, laden with paperwork, and inconsistently administered by the ports.  To avoid these pitfalls, consider filing entry summaries in ACE instead of ACS.    By doing so, you can bypass the PEA process and avail yourself of the Post-Summary Correction (PSC) process, which not only is paperless (electronic) but allows importers to file corrections up to 270 days after the date of the entry (currently 10 days if filing in ACS).