Thursday, November 29, 2007

2008 Government Publications

It’s that time of year again, when we field a number of questions about when the 2008 government publications will be available from Boskage.

The 2008 government publications are likely to be released within the first six weeks of 2008. The trade does not have an exact date of release because the government entities responsible for delivering these titles do not give out a release date in advance of publication. However, if the last three years are any indication of a trend, the ITC (HTSUS) Census Bureau (Schedule B), and Treasury Department (CBP Regulations) will release in mid to late January of 2008, and the Bureau of Industry and Security (Export Regulations) will release in late January to mid February of 2008. We’ll post blog entrys when each publication is released so that you’ll have the latest information.

Boskage stands ready to ship the new HTSUS and the rest of these subscriptions as soon as they become available. Order your subscriptions now to ensure your company will remain in compliance by using the most current editions of the required publications.

All subscriptions through Boskage include printed supplements throughout the calendar year for free*.

Click on the publications below for a complete description of the publication and pricing.

2008 Harmonized Tariff Schedule (HTSUS)
2008 U.S. Customs Regulations (19 CFR Title 1, Parts 0-199)
2008 Export Administration Regulations
2008 Updates to the 2007 Schedule B

Looseleaf editions include all shrink-wrapped pages and all updates.

Deluxe editions include looseleaf pages (with all updates) heavy-duty D-ring binder and indexing tabs.

*Supplements are included at this price. However, re-prints (any edition comprising more than 50% of the original) will be billed at cost.

Tuesday, November 27, 2007

Pass Rate For October 2007 Customs Broker Exam

From the CBP:

Number of candidates: 1387
Pass Rate: 9.2%

Credit was given to all for 4 questions.

Friday, November 16, 2007

CBP Posts October Exam Answers

After weeks of waiting, the answers for the October Customs Brokers Exam have been mailed to the anxious examinees and posted to the CBP website for the public. First, we want to congratulate all of you who passed! We would like to hear your comments about how you studied, what worked best for you and any other comments about the exam. Next, we want you to know that there appear to be some typographical errors related to references on the Exam Key dated November 13, 2007. Click here to view the correct references.

We were not surprised that questions were thrown out, but it was a little surprising that four questions were eliminated. Congratulations, everyone automatically answered four questions correctly and earned five free percentage points (4 x 1.25). Now all you need is 70 points, which equates to answering 56 questions correctly.

So what if you only answered 54 or 55 questions correctly? Should you give up and say “maybe next time?” No! Look at the answers to see if there are any questions that could be protested. You haven’t lost anything by protesting a question, but with the right protest, you may go from failing to passing and obtaining your license.

We have analyzed the questions and answers and found five questions that we believe could be subject to protest. Those questions are 19, 21, 42, 45 and 47. Click here to see the comments about Question 45. In future postings to the blog we will provide additional information about these potential protest questions. We welcome your comments and suggestions on these questions and any others you think might be subject to protest. Remember, you haven’t lost anything by filing a protest and you may save yourself the time and money necessary to take the test again.

Thursday, November 8, 2007

Foreign Suppliers Can Help Importers

Foreign suppliers are often overlooked in the import process, yet they must perform certain tasks in order for the foreign goods to be allowed entry into the U.S. Sometimes foreign entities are only familiar with the laws of their own country and do not realize that the U.S. has laws that are different. The manner in which the foreign supplier fulfills their obligations can expedite or delay the import process. If the importer provides the foreign supplier with instructions about preparation of documents, country or origin, cargo security and other requirements, then the foreign supplier will have a better understanding and the tools to help them help you.

Wait a minute! You may be thinking that you don’t even have time to train your own staff and other departments in your organization. How can you be expected to train foreign suppliers? However, it’s not that hard and the small investment in time will make your life easier because the quality of the documentation and compliance with the company’s requirements will be improved.

Here are some suggestions on how you can educate your foreign suppliers.

1. Provide the foreign suppliers with standard guidelines for import shipments. The guidelines can be published online, provided with each purchase order, or some other method. You may also want to collaborate with others in your supply chain, such as buyers and logistics, to create a document that covers the importation of these products from the time an order is placed to the time payment is made. What should be included in those guidelines? The following is a brief list of items that should be addressed:

A. Company Contacts
Your guidelines should provide names, phone numbers and email addresses for key contacts related to imports, exports and logistics.

B. Documents
This section should provide a list of all documents that are required for your shipments along with any specific requirements for each document. For example, the commercial invoice is a key document and it is important for the foreign supplier to know what information is required to be included on the document. You could include a link to 19 CFR 141.86 or provide the list in your own format. If your company imports goods from a NAFTA country, remember to include the production of the CBP 434 NAFTA Certificate as a required document.

C. Country of Origin Marking
The requirements for country of origin marking should be explained along with any special requirements your company may have for marking of the merchandise and packaging. Since failure to mark or improperly marked merchandise creates additional work for the importer and potential penalties from CBP, some companies include a provision for charge-backs for improper marking. Provide a list of responsibilities for the supplier to assist them in marking the merchandise correctly.

D. Valuation - General
Determining the value for goods is difficult enough for importers, so explanation of these requirements to the foreign suppliers may be even more difficult. Consider introducing this topic with a summary of the importance of declaring the value and being able to support these calculations if requested. Then provide a list and brief explanation of the key components of value such assists, commissions, packing and related parties. If you are aware that certain components affect your shipments, such as related party transactions, place more emphasis on these topics.

E. Free of Charge Goods
Include some brief instructions on the proper declaration for free of charge goods. It is important for foreign suppliers to properly declare the values for the free of charge items they send and it will save you time having to contact the supplier to obtain the values in order to obtain release of the goods from CBP. The supplier may have difficulty understanding the importance of declaring accurate values since the good are being supplied free, so a good explanation and example may help get the point across.

F. Repaired Goods
Explain that imported merchandise that is subsequently exported for repairs and re-imported could be charged duty on the entire value of the shipment unless the return shipment is properly identified as being “repaired goods returned.” The foreign supplier responsible for the repairs must complete documentation that provides the value of the goods and value of the repair. Explain that for purposes of paying Customs duties, it is irrelevant that the goods may have been under warranty or that the repairs are performed at no cost to the importer.

G. Packaging and Labeling
In addition to the country of origin markings, each company will have specific packaging and labeling requirements based on the type of products imported. You should include information such as size and type of boxes, pallets and special marking required on the cartons.

H. Transportation
While transportation issues may not be the responsibility of the Import Compliance Department, your Logistics Department may want to contribute to these guidelines. This section usually contains information about the use of ocean and air carriers, as well as forwarders. You may want to specify carriers and when it is allowable to ship air versus ocean.

I. C-TPAT Security Requirements for Suppliers
For those companies that are members of C-TPAT, you must assess the security policies, procedures and processes of your business partners. Use this section to convey your company’s commitment to C-TPAT and provide links or references to the relevant C-TPAT Security Criteria for Manufacturers.

J. Accounts Payable
This section should include the requirements for submitting invoices for payment and provide the methods of payment used by the company.

2. Check out the bcpLearning courses.

The basic suite of courses contains a short course designed specifically for foreign suppliers. This course describes the basic process of importing for a U.S. company from beginning to end. The course then focuses on the roles of Foreign Suppliers in the process, including complying with C-TPAT guidelines, providing complete documentation packages, and preparing documents for express courier shipments. This course also includes a foreign supplier guidelines document, which describes the information included in this article and additional topics in more detail.