Priority Trade Initiatives

As most of the trade community may have noticed, U.S. Customs and Border Protection has been updating their web site. It may take a little extra effort to find some of the information and get used to the new format, but in time, we will enjoy the new features and expanded information. One of the new areas created during the update is the Priority Trade Issues (PTI). PTIs are identified as high-risk areas that are likely to cause significant revenue loss, economic risk to U.S. industry or health and safety concerns to citizens.

Currently, the following seven areas are identified as PTIs:

• Agriculture


• Antidumping and Countervailing Duties


• Import Safety


• Intellectual Property Rights


• Penalties


• Revenue


• Textiles

Click HERE to learn more about each PTI.

BIS Principles of Export Compliance

With increased scrutiny of export compliance, exporters should have an effective compliance system in place. At the recent BIS Export Control Forum in Newport Beach CA, Assistant Secretary for Export Enforcement Darryl Jackson gave a presentation outlining nine principles of export compliance used to evaluate the effectiveness of an export compliance program and determine whether mitigation of an administrative penalty is warranted. These nine principles include:

· Meaningful Risk Analysis
· Written Compliance Programs
· Responsibility for Oversight by a Senior Official
· Adequate Employee Training
· Adequate Customs and Transaction Screening
· Compliance with Recordkeeping Requirements
· Internal System for Reporting Violations
· Internal and External Reviews/Audits
· Remedial Actions to Address Violations

Similar to import compliance programs, exporters must be able to demonstrate that the nine principles are applied in business transactions and not just something put on paper to satisfy the government. The export compliance programs must also be reviewed and updated to reflect changes in business practices and government regulations. Click on the following links to view Jackson’s speech and presentation.

Creating Your Import Compliance Procedures

In March, we discussed the importance of having import compliance procedures and promised that we would discuss creating and customizing these procedures in April. In order to obtain all of the benefits having import compliance procedures offer, it’s important to create procedures that will be supported by executive management and useful for employees. So, how do we get started?

We’ve provided the following suggestions to help you develop your import policies and procedures:

• Obtain support of executive management.



• Identify CBP-related laws and regulations, import activities, organization and products that may require procedures.



• Draft an outline or table of contents of procedure topics.



• Collect and review any existing procedures, making notes for necessary changes.



• Collect information that will help you draft the policy or procedure.



• Select a format.



• Create drafts of procedures.



• Review the drafts and allow functional areas affected by the procedures to review and provide feedback.



• Review feedback and make changes.



• Prepare final document.



• Obtain final approval.



• Assemble the manual and make copies and/or upload procedures for employee access when using electronic media.



• Implement and communicate new procedures.



• Provide training when necessary.



• Schedule review and update.

Now that you have determined the need for the procedures and have possibly taken the first few steps to creating your own procedure manual, how are the procedures written? When writing standard operating procedures, there are a number of different ways to organize and format them. Many people fear the task of writing procedures because they do not like to write, or may not feel that their writing skills are sufficient. Generic templates can make the task more manageable because the basic information has already been created. All you have to provide is the information that pertains to your company. Your goal is to create a document that is factually and legally accurate, useful, and easy for the reader to understand. Let's look at some suggestions that may help you when writing policies and procedures.

Policies should be clear, concise, simple, understandable, factual, and logical.

You should also consider the following tips:

• Avoid using information that may be quickly outdated, such as names of employees.



• Spell out acronyms the first time they are used.



• Include step-by-step instructions for completing forms.



• Use graphs, charts, drawings, and illustrations as required.



• Be consistent with use of headings, bold, underline etc.



• Divide into sections that contain materials related to one topic or process.



• Use action verbs to begin sentences and lists when possible.



• Simplify and summarize difficult information.

Click HERE to view a generic sample of a General Order procedure.

When supported by management, your organization’s import compliance procedures can serve as an example for an overall corporate commitment to compliance. If well written, properly used and reviewed regularly, your company should experience higher levels of quality and increased employee and customer satisfaction.

Special HTSUS Change Package - Boskage Exclusive

The International Trade Commission (ITC) has revised the 2008 Harmonized Tariff (HTSUS). However, the ITC has elected NOT to print these changes.

We understand that many of our customers will want to update their printed editions, and we have a limited number of printed change packages available for sale to our customers only. This is the only available print edition of this revision.

Order now as these print editions are limited.

NOTE: If you purchased the HTSUS through Boskage, this revision is not part of regularly printed government supplements, which will still be sent to you at no charge upon release as part of your 2008 subscription.

The special change package is 198 pages. The price is $24.50 with $6.00 shipping/handling.

Please click here to get your HTSUS special change package.

If you are a Boskage OneSource CD subscriber, these changes will be made to your software the next time you access OneSource.

If you would like to purchase a special OneSource HTSUS that includes the current changes, please click here to have your CD sent today.

Potential Answers for April 2008 Customs Broker Exam

As many people sit on pins and needles waiting to see the answers posted for the most recent Customs Broker’s Exam, our very own Wizard has taken the exam and provided a list of possible answers and related regulations where the answers were found. We never know when CBP will post the answers and the wait feels like forever. The answers for the October 2007 Exam were not posted until November 13.

We invite you to post your answers, explanations, arguments and other comments. Obviously, Boskage Commerce Publications cannot guarantee the accuracy of these answers since CBP has the one and only answer key, but the Wizard has an excellent record of achieving a score of better than 90%.

Click HERE to view a copy of the Wizard’s answers for the April 2008 Exam! Additional commentary on the exam will be available to our students soon.

Note: The Wizard had the most difficulty answering the questions marked by an “asterisk” and highlighted in purple.