customs enforcement actions for c-tpat non-compliance · may 2010 managing imports & exports 2...

MANAGING IMPORTS & EXPORTS

MAY 2010 www.compliancemaven.com

ISSUE 01-14 WWW.COMPLIANCEMAVEN.COM MAY 2010

ALSO IN THIS ISSUE....

Customs Enforcement Actions for C-TPAT Non-Compliance continued.........................................2NAFTA - Part 3............................................................3, 8Ask The Experts..............................................................4Good News for U.S. Exporters.....................................5Understanding the Differences Between the CISG and the UCC.................................................................6, 7AES and the FTR (Foreign Trade Regulations)Did You Know.............................................................7, 9Import-Export Managers’ Calendar...........................10Upcoming Educational Seminars...............................11

Customs Enforcement Actions for

C-TPAT Non-ComplianceBy Rennie Alston

Many members of the international supply chain community have taken the positive step towards the enhancement of their global supply chain security management process by joining the Cus-toms Trade Partnership Against Terrorism program (C-TPAT). The C-TPAT program is one layer in U.S. Customs and Border Protection’s (CBP) multi-layered cargo enforcement strategy. Through this program, CBP works with the trade community in adopting tighter security measures throughout their international supply chains. In exchange for adopting these stronger security practices and after verification by CBP that the measures are in place, CBP generally affords C-TPAT members reduced inspections. C-TPAT is a voluntary program with a “trust but verify” focus and, as such, the program must take immediate action to suspend or remove members that are not in compliance with the pro-gram’s minimum security criteria.

The C-TPAT program has had large success in its membership enrollment and certification process. It is very important to note that a continued com-mitment to all elements of the minimum security criteria is mandatory in this voluntary program. This is not a one and done effort that only requires attention to detail at the initial point of certification. The C-TPAT program requires a diligent effort on a

continued basis to monitor and enhance a company’s security management process related to their interna-tional trade supply chain activities through its direct supply chain process. CBP has a definitive enforce-ment and appeal process for program participants that are found to be in non-compliance with the C-TPAT security criteria.

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Customs Enforcement Actions for C-TPAT Non-Compliance continued…

Many members of the international trade community are utilizing their influence to ensure that their busi-ness partners participate in the C-TPAT program to compliment their international supply chain relation-ships. Careful diligence continues to be enhanced by such business partners such as the monitoring of the status verification interface data (SVI) information which is designed to provide current enrollment, cer-tification and validation information for program par-ticipants. It is critical for participants to keep current their certified or validated status in the program with a dedicated effort toward security compliance.

It is very important to note that C-TPAT members may be suspended or removed from the program for several reasons including, but not limited to, the following: narcotics seizures or other security related incidents such as human smuggling; failed validations or lack of compliance with C-TPAT requirements regarding supply chain or other security measures; failure to provide required information or filing false or mis-leading information; or actions or inaction that shows a lack of commitment to the program. The authority cited and provided for in the SAFE Port Act, provides limitless ability to the Commissioner of Customs and Border Protection to take actions to protect the national security of the United States. Importers must note that a continued dedication to C-TPAT management is es-sential.

The C-TPAT Headquarters (HQ) Program Direc-tor makes the final decision to suspend or remove a member based on all available information, includ-ing reports and recommendations made by C-TPAT Field Managers. In certain aggravated circumstances, companies may be immediately removed from the program, for example, when they are found to have provided false information, have demonstrated in-adequate security, or have demonstrated a flagrant disregard for the program’s requirements. In other in-stances, which may not be as egregious, but are none-theless significant, a company may be suspended from C-TPAT with an opportunity to resume membership once it comes into compliance with program require-ments.

To be reinstated into the program after an incident or violation, the company must agree to a corrective action plan, which identifies specific objectives and time frames within which those objectives should be reached. In addition, the company must consent to un-announced visits by C-TPAT staff to moni-tor progress. In the case of a failed validation, the company must demonstrate that it has successfully addressed all vulnerabilities and complied with all other requirements before being fully reinstated.

If a company is suspended or removed, they have the right to appeal this decision to CBP headquarters. Appeals must include all relevant information that demonstrates how the company has addressed the issues which resulted in the suspension or removal, or provide corrected factual information in the case where a company claims that a mistake of fact or other misunderstanding has resulted in the suspen-sion or removal. CBP will decide the appeal in a timely fashion upon such review and determination of the facts.

The only way to avoid suspension or removal: C-TPAT members are required to ensure they are in full compliance with the minimum security crite-ria and be aware of, and responsive to, mandated timeframes established by CBP relative to requests posted in their individual C-TPAT web portal for such deliverables as validation response transmis-sions, written affirmation of compliance request to security procedure elements of their profile, previ-ously confirmed action item statements and valida-tion action items..


MAY 2010 www.compliancemaven.com 3

NAFTAPart 3

By Kelly Raia

Parts 1 and 2 of this series reviewed the overall NAFTA Certificate and Fields 1 through 6. This month’s exciting focus will reveal the perils of Field 7 – Preference Criterion.

This is the crux of the NAFTA Certificate, the sun of our solar system, the core of the….okay you get it. This is the basis of the whole NAFTA. For each item we have listed on the Certificate, we are now going to have to provide how we made our determination in order to be entitled to preferential tariff treatment.

Preference Criteria A: “wholly obtained or pro-duced entirely” in one or more NAFTA territories. This means NO FOREIGN PARTS! There are few manufactured items that contain no foreign parts so be careful when receiving certificates from suppliers that indicate “A” and double check with them because Customs may be double checking with you. NAFTA specifically lists examples of wholly originating goods: live animals, born and raised in NAFTA territory, fish caught by a regis-tered flag vessel of a NAFTA territory, mined min-erals and space rocks. Yes, I know it’s weird. They threw that into the NAFTA to make sure the person reading it is still awake.

Preference Criterion B: “tariff change and regional value content”. According to NAFTA, “the good is produced entirely in the territory of one or more of the NAFTA countries and satisfies the specific rule of origin that applies to its tariff classification. The rule may include a tariff classification change,

regional value content requirement or a combination thereof.” Piece of cake, right?

Speaking of cakes….let’s talk about fishcakes. Yes, like Mrs. Paul’s fishcakes (HTS #1604.20.2000). The fishcakes were made from fresh haddock imported from Scandinavia (HTS #0302.62.0000). We compli-ance professionals have heard of substantial trans-formation and possibly even common sense. Well, it’s not enough to judge NAFTA without the specific Rule of Origin. So I now look up the Rule of Origin for my product – the fish cake. The rule reads: A change to heading 1601 through 1605 from any other chapter. Well, my fresh fish falls under chapter 3 and my fishcakes are under chapter 16 so I qualify for NAFTA under Preference Criterion B because I meet the specific Rule of Origin.

Let’s throw in a ‘what if’ here…what if I imported the fishcakes and am bringing them into the U.S. to throw a tomato on top of them? I’m jazzing these up to serve them to Chef Ramsey up in Canada. The to-matoes are from a farm on Long Island, (btw: NAFTA Preference Criterion A) but those fishcakes are from Scandinavia. Am I going to qualify for NAFTA under Preference Criterion B? Did I meet the appli-cable tariff change “from any other chapter”, I started in chapter 16 and ended there. No can do.

That example demonstrated tariff change but what is the regional value content and what can be included in regional value content? I’m glad you asked…if you were considering getting a cup of coffee, now would be a good time.

There are two methods of determining regional value content: transaction value method and net cost method. One must add up the costs involved in making the product. Some costs will be considered originating and some will be excluded. A percentage of the costs is the regional value content.

There are two methods for calculating regional value content: transaction value and net cost. The net cost method must be used if there is no transaction value or the transaction value is not acceptable. Remember your valuation concepts? Regional value content includes: direct materials, indirect materials, direct labor and overhead.

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MIE’s ‘Ask the Experts’ team -- Kelly Raia, Vice President & Senior Consultant, Randi Keenan, Assistant Vice President and Senior Consultant and Sarah Reynolds, Senior Consultant, all from The World Academy -- answer readers’ import or export related questions. Readers may submit questions to [email protected] - This month’s column is by Dennis Salvey, Trade Compliance Professional, who has been a compliance manager for many years. This is a little different format than our usual ‘Ask The Experts’ -- it’s more ‘Compliance Humor’ -- Enjoy!

Question: If an American citizen shoots a foreign national from Kosovo in the U.S. with a shotgun made in the U.S. and controlled under the ITAR, but the bullet was made in Mexico, qualifies for NAFTA and is controlled under the EAR having an ECCN of 0A984, and the bullet stays lodged in the victim, what happens?

Answer:

BIS ExportThe American citizen needs a license because Kosovo is controlled for export under “crime control”.

BIS Deemed ExportThe American citizen needs a BIS license to share the bullet technology with a foreign citizen.

ITARThe American citizen needs a TAA to share the shotgun technology (defense service) with the Kosovo citizen.

U.S. ImportThe bullet was imported originally from Mexico under 9306.21.0000, but has been through a substantial transforma-tion and is now incorporated into a human being.

NAFTAThe bullet no longer qualifies for NAFTA as it has been incorporated into a human (see U.S. importing) and the re-gional value content of the victim is predominantly Kosovo.

Question: Now same scenario, except the bullet passes through the victim, what happens?

Answer: BIS ExportNo license required as this is a transshipment.

BIS Deemed ExportNo license required as it is a deemed transshipment and the victim is very unlikely to share the technology with any-one.

ITARAmerican citizen needs a DSP-73, even though the bullet is controlled under the EAR, the ITAR “see-through” rule comes into effect because the bullet passed all the way through the victim.

U.S. ImportingThe bullet upon exiting the victim must be declared under 9801.00.2600.

NAFTAThe victim now qualifies for NAFTA because his Kosovo regional value content exited his body along with the bullet. The victim has under-gone a substantial transformation in the U.S. from alive to dead satisfying the tariff shift rule.

Ask The Experts



Good News for U.S. Exporters

By William Laraque

The analogy to Paul Revere is tempting. Like Paul Revere, I too ride through New England with a warning. The analogy ends there in that the news is fortuitous, not dire, concerns U.S. exporters and has a beneficial portent for U.S. jobs and economic development. It is not the British who are coming, but what is arriving as of 1 May is much needed help for a resurging U.S. export capability.

On 1 May, 2010, the Export-Import Bank of the U.S. (Eximbank) will announce that it has changed its U.S. content requirements. This is a big deal because U.S. businesses will now have easier access to export credit insurance and export financing. The effect will be to assist the U.S. exporter in:

• Expanding international sales

• Boosting borrowing power

• Speeding cash flow

• Entering new markets

• Mitigating Risks and Losses

I have been financing international trade for more than 30 years. Never, in my recollection, has there been a wider gap between what finan-cial institutions and underwriters say they can do and what they deliver on. This distinction is critical for exporters who cannot afford to spin their wheels in looking for appropriate support when the global climate for buying U.S. export-ed goods is so promising.

The less restrictive U.S. content terms of Exim-bank are significant because they can be com-bined with buyer financing to help the export-ers of U.S. made capital equipment. It will become easier to qualify U.S. goods as meeting the U.S. content requirement of Eximbank.

It is a well kept secret that a select group of U.S. banks and financial institutions are actively using their reps to call on companies in Brazil, Mexico, Colombia, Turkey, the UAE and other fast growing countries. These buyers are then made to realize that Eximbank guarantied or insured buyer financ-ing is available to support these buyers’ purchases of U.S. manufactured goods.

There are advantages to both buyers and sellers in utilizing buyer financing, namely:

• The financing is not dependent solely on the financial health of the U.S. exporter. In a time of global economic recession, this is particularly significant.

• The buyer gets access to financing where terms and interest rates are attractive when com-pared to rates prevalent in their home countries.

• The financing institution is aware that the country risk is acceptable to Eximbank (ask me about Eximbank’s Country Limitation Schedule).

• The financing institution has reps in the buyer’s country and will be able to obtain the req-uisite credit information on the buyer.

• Encourages the export of used equipment with Eximbank supported financing.

• 1 to 5 year repayment, exceptionally 7 years and <$10 million.

• 15% advance payment, 85% financed amount.

Our U.S. based ARI customers are presently selling to Dubai, Mexico, Brazil and S. Korea by using the described technique. Never has there been a better time to export U.S. made capital equipment.



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Understanding the Differences Between

the CISG and the UCC

By Sarah Reynolds

The United Nations Convention on Contracts for the International Sale of Goods governs contracts for the sale of goods internationally. It was sponsored by the United Nations and opened for national ratification in 1980. The objective of the CISG is to eliminate ambiguity caused by different domestic laws con-cerning the international sales of goods. The Uniform Commercial Code, which was first published in 1952 and considered to be one of the most impor-tant legislative measures in U.S. commerce history, was adopted by every state except Louisiana. It is a comprehensive set of laws that pertains to domestic transactions and provides harmonization of the law of sales and other commercial transactions within the United States.

International trade has increased over the years which created the need for international law to pro-vide uniformity, not only for domestic transactions but also for international transactions. It is important to have an understanding of the CISG and the UCC and how they may apply to your business transac-tions. Without knowledge of their existence and ap-plicability to your transaction, you can leave yourself open to an array of problems should a dispute arise.

If you are currently involved in domestic transactions and are considering expanding your business glob-ally, it is imperative to understand that your interna-tional transaction may be subject to the provisions of the UNCISG and not the UCC, which would normal-ly apply to your domestic business dealings.

Currently, they are 74 states party to the UNCISG. Countries that have ratified the CISG are referred to within the treaty as ‘Contracting States’. When entering into a business transaction with one of these “Contracting States”, you must be aware that the CISG will be applicable and not the UCC.

The CISG applies only to international commer-cial transactions, i.e., sales between merchants of goods. Among other limitations, it does not cover consumer sales, auction sales, sales of negotiable instruments or securities or sales of ships, vessels or aircrafts.

However, should parties to the transaction not want the CISG to be applicable; there is the option for the parties to the sales contract to “opt out” of the CISG. Specific language is required dictating that the other law will apply, as well as stating that the CISG will not apply in case of a dispute.

The CISG’s rules closely follow Article 2 of the UCC which is in force in 49 of the 50 states, how-ever it is very important to understand that there are differences between the CISG and the UCC and you should familiarize yourself with these differ-ences in order to make an informed decision as to which law both parties want to enter into contract under.

Differences can be found in areas such as in the formation of contracts, offer and acceptance and examination and notice. In the case of examina-tion and notice, under the CISG, the buyer must examine the goods as soon as feasibly possible and notify the seller of any lack of conformity and within a reasonable time after a discrepancy has been discovered, or at the very latest, within two years of delivery. If the buyer fails to perform an inspection of the goods or file a complaint, the buyer forfeits their right to reject the goods and the right to claim damages. The UCC also contains provisions that allow the buyer to refuse delivery of defective or non conforming goods. These provi-sions are known as “rejection” and “revocation of acceptance” while under the CISG, they are referred to as “avoidance of the contract”. In both the CISG and the UCC, these terms refer to a party’s right to cancel a contract.

Also, under the CISG, the seller is afforded pro-tection against the possible failure of the buyer to make payment. If it is apparent that the buyer may be unable to make payment for the merchandise, the seller may advise the buyer that he will suspend delivery or withhold release of the goods. However, the seller must move forward with the delivery of the goods if the buyer then provides adequate assurance of payment. Under the UCC, the seller has no right to withhold delivery due to the fear of non-payment, unless authorized to do so under the contract.



Editorial Advisory Board

Marilyn-Joy Cerney, Esq. Gerry Doyle Robert Core Marie Cabral Attorney Attorney Foreign Trade Zone Mgr Imp/Exp Compliance Dir Cerney Associates, PC Doyle & Doyle L’Oreal USA America II Electronics, Inc. Kay Georgi Thomas A. Cook Karen West Lydia Moya-Kiste International Trade Attorney Managing Director CEO Imp/Exp Compliance Mgr Washington, DC Office American River Int’l Earth Customs Inc. Unipart Services America (Export Controls/Trade Remedies) Earth Cargo Inc. Partner, Arent Fox PLLC Jerina Barutis Customs Attorney

Understanding the Differences Between the CISG and the UCCcontinued…

Another example is that the UCC recognizes that if a contract is made by mail, the time of acceptance of the offer is the instance the acceptance is mailed, while un-der the CISG, an offer is accepted at the time of receipt of the offer.

Therefore, it is important to understand and famil-iarize yourself with the laws that may govern your transaction and the possible options that are avail-able and may best suit your sales contract, and also to understand your obligations under these laws. It is never wise to enter a contract blindly, and while it may sound cliché, knowledge is power.

AES and the FTR(Foreign Trade Regulations)

Did You Know?

By Randi Keenan

Most of us who are involved with exports are aware of most of the “working” parts of the FTR as it relates to AES and EEI’s. For example, we know that we must file within specified time frames, prior to export, depending on the mode of transport. We understand that accurate and timely filing is one way to avoid fines and penalties. We check, we double check, we change anything that is incorrect, and once all is in order, we add the EEI/AES to our record keeping process and call it a day.

But did we ever really take the time to actually read the FTR (15CFR part 30) to get the “whole picture” of these regulations? Are there any other requirements that we must adhere to, other than the obvious? Most of us have not delved in deeply, but we should. There are various key parts of the FTR that most of us are unaware of. It is my intention to identify just a few of the commonly “overlooked” parts of these regulations.

CONTINUED ON PAGE 9



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NAFTA Part 3continued…

Website Feature of the Month

www.customsinfo.com

customsinfo.com is a website providing such features as denied party lookup, Global tariffs, trade tools and ECCN finder. The classification support provided by the website enables clients to obtain domestic and for-eign classifications which could prove to be a valuable tool when determining overseas costs for export ship-ments. The website also offers multi language docu-ments which could facilitate your international trans-action while the ECCN finder helps exporters match Schedule B numbers with ECCN numbers to help find items that have been flagged by the US government for export control. Subscription required.

Direct materials: components physically incorpo-rated into the finished item.Indirect material: materials used in production of the item but not physically incorporated. (safety glasses and gloves worn by employ-ees in manufacturing the item)Direct labor: salaries of employees directly involved in the productionDirect overhead: overhead costs directly associated with production of those items (electricity)

Once you have determined the appropriate numbers, we plug them into the formulas below. Yes, that’s right we’re talking formulas and mathematics.

Transaction Value MethodRegional Value Content = TV – VNM x 100 TV

Net Cost MethodRegional Value Content = NC – VNM x 100 NC

TV: Transaction ValueVNM: Value of non-originating materialNC: Net cost

Upon reading the NAFTA rule of origin, you will know the percentage you need to meet in order to qualify. If you meet the percentage for your product, you have qualified and can proudly enter a “B” in Field 7.

Next month….We conclude our NAFTA series with Preference Criteria “C”.



Publisher: Rennie Alston ~ Editoral Staff: Randi Keenan, Kelly Raia, Sarah Reynolds ~ Managing Editor: Tracy Lenok

Managing Imports & Exports (ISSN 1553-0752) is published monthly for $437 per year by the PACMAN Association, 614 Progress Street, Elizabeth, NJ 07201. © 2009. PACMAN Association All rights reserved. A one-year subscription includes 12 monthly issues plus regular fax and e-mail transmissions of news and updates. Copyright and licensing information: It is a violation of federal copyright law to reproduce all or part of this publication or its content by any means. The Copyright Act imposes liability of up to $150,000 per issue for such infringement. Information concerning illicit duplication will be gratefully received. To ensure compliance with all copyright regulations or to acquire a license for multi-sub-scriber distribution within a company or for permission to republish, please contact PACMAN’s corporate licensing department at 877-PACMAN8, or email [email protected]. Periodicals postage paid at Elizabeth, NJ and additional mailing offices. POSTMASTER: Send address changes to PACMAN Association, 614 Progress Street, Elizabeth, NJ 07201, 877-PACMAN8 or e-mail [email protected]

For example: At some point in your exporting career you may have been (or may be) asked by someone overseas to provide them with a copy of the AES transmission for their specific shipment. Did you know it’s a violation of the regulations (as per 15CFR 30.60) for you to share the AES information with foreign entities? If you share the AES with foreign entities, you are subject to civil penalty actions.

Or, how about this one: In a routed export, we are probably all aware that the “written authorization” comes from the foreign principal party and is issued to the U.S. agent of that FPPI. But, did you know that as per section 30.3(e)(1), if you make an agreement with the FPPI that you (the USPPI) will file the AES in a routed export transaction, then you (the USPPI) must have written authorization from the FPPI that gives you authority to file AES in this situation?

Another gem that is contained within these regulations is found in section 30.3(e)(2). Here we

read that in a routed export, the USPPI has the right to request a copy of the written authorization that was given by the FPPI to the U.S. authorized agent who will be filing AES. This is your RIGHT as a USPPI and you should be obtaining a copy of this authorization for your records. This should become common practice and should be included in your export SOP.

Or, how about the proper valuation of export ship-ments according to the regulations? Those of us who are involved in import activities are probably aware that valuation is a science under the CBP regulations (19CFR) that involve 5 main principles. Well on the export side, there is a similar requirement of valuation. The value of an export shipment for purposes of filing AES is found in the definitions section in 30.1(c). Here it states that the export value on your EEI will be….“The value of the goods at the U.S. port of export. The value shall be the selling price (or the cost if the goods are not sold), including inland or domestic freight, insurance and other charges to the U.S. seaport, airport or land border port of export…” The moral of this story is to dig deeper! Learn all that you can, read all that you can, and you will be amazed at how quickly you can become an expert in yet another area of export compliance.

If you have any questions or comments on the Foreign Trade Regulations or AES in general, please feel free to contact me directly at [email protected]

AES and the FTR (Foreign Trade Regulations) Did You Know?continued…



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Contact:www.theworldacademy.com

Email: [email protected]

Advanced Import/Export Operations, Documentation & Compliance ManagementJune 22-23, Detroit, MI July 19-20, Chicago, IL September 20-21, Newark, NJ October 25-26, Los Angeles, CADecember 13-14, Ft. Lauderdale, FL

C-TPAT Certification Training WorkshopJune 10, Chicago, IL July 23, Chicago, ILAugust 4, Newark, NJ September 1, Orlando, FLSeptember 23, Newark, NJ October 28, Los Angeles, CADecember 16, Ft. Lauderdale, FL

Drawback WorkshopJune 22, Chicago, IL September 21, Newark, NJDecember 16, Ft. Lauderdale, FL

Establishing Import/Export Compliance ProceduresMay 17-19, Newark, NJ August 2-3, Newark, NJOctober 13-14, Chicago

Hazardous Materials TrainingAugust 9-10, Chicago, IL

INCOTERMS and Related Global Trade Issues June 11, Chicago, IL June 25, Detroit, MIJuly 22, Chicago, IL August 6, Newark, NJSeptember 3, Orlando, FL September 24, Newark, NJOctober 29, Los Angeles, CA December 17, Ft. Lauderdale, FL

Letters of CreditMay 27, Newark, NJ October, 20, Newark, NJ

Managing HTS (Harmonized Tariff Schedule)June 24, Detroit, MI July 21, Chicago, ILAugust 5, Newark, NJ September 2, Orlando, FLSeptember 22, Newark, NJ October 27, Los Angeles, CADecember 15, Ft. Lauderdale, FL

PACMAN - Import/Export Compliance Certification Workshop & ExamMay 11-12, Newark, NJ May 13, Newark, NJ (Annual Meeting)November 15-16, San Jose, CA

IMPORT-EXPORT MANAGERS’ CALENDAR



IMPORT-EXPORT MANAGERS’ CALENDARMay - June, 2010 Webinar Schedule

**ALL WEBINAR TIMES ARE EST**

May 10, 2:00 pm - 3:00 pmExporting to Sanctioned Countries

May 24, 2:00 pm - 3:00 pmISF compliance management "Are you prepared to manage the total ISF Compliance responsibility as an Importer?"

June 21, 2:00 pm - 3:00 pmCompliance overview for senior management - addresses all compliance issues in an overview format for seniormanagement

June 28, 2:00 pm - 3:00 pmHow to manage international trade compliance risks in a routed transaction

Contact:www.theworldacademy.com

Email: [email protected]

Bureau of Industry and Security (BIS): www.bis.doc.gov

May 5th-6th Complying with U.S. Export Controls Newport Beach, CAMay 20th-21st Complying with U.S.Export Controls Las Vegas, NVMay 25th-26th Complying with U.S.Export Controls Wichita, KS

American Management Association (AMA): www.amanet.org

July 26th-28th Import/Export Procedures & Documentation Chicago, ILOctober 4th-6th Import/Export Procedures & Documentation Atlanta, GA

Upcoming Educational Seminars --



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customs enforcement actions for c-tpat non-compliance · may 2010 managing imports & exports 2...

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