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CONSUMER PRODUCT SAFETY COMMISSION – 1USG
This article has been provided the National Customs Brokers and Forwarders Association of America (NCBFAA) for your information: CPSC Webinar Provides Insight on Managing the 1USG Messaging in ACE Consumer Product Safety Commission (CPSC) officials joined with customs brokers in a stimulating and informative webinar on CPSC’s 1USG Messaging at Import on June 18. CPSC panelists Deputy Director Sabrina Keller and International Trade Specialist John Blachere explained and clarified key elements of their newly implemented messaging system. Customs broker, Adam Lees of Geodis, who has experience with the messaging system since the original pilot was launched over a year ago, shared useful pointers and best practice tips. Mike Lahar of AN Deringer and chairman of the Regulatory Agencies Committee (RAC) kept the conversation moving as moderator, highlighting areas of confusion and concern. John Blachere explained that whenever a broker files an entry for a product in one of 320 targeted HTS categories of CPSC-regulated products, the broker will receive an “Under Review” message in ACE from the CPSC. This message does not mean the product is being held or subject to physical exam, it simply signifies that CPSC is looking at the entry documentation. Following the Under Review message, a broker will in most cases receive a “May Proceed” message. Less common, the broker may receive a “Hold Intact” or “Intensive Exam Requested.” Blachere... Read More
APHIS – LACEY ACT PHASE VI – August 1st, 2021
The following article submission has been provided by the NCBFAA (The National Customs Brokers and Forwarders of America): APHIS Lacey Phase VI Implementation Will Begin Aug. 1 October 1st. NOTE/ UPDATE – Last week, the NCBFAA Regulatory Agencies Committee (RAC) reported that the USDA’s Animal and Plant Health Inspection Service (APHIS) Lacey Phase VI would be delayed one month – to Aug. 1. At the last minute, however, APHIS Administrator Kevin Shea requested a delay until Oct. 1, 2021, to give the trade more time to prepare. A July 2 Federal Register provides further details. U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) Lacey officials informed the NCBFAA RAC that the Phase VI implementation will not occur on July 1. A Federal Register notice will be published any day announcing that the APHIS Lacey Phase VI implementation will instead occur on Aug. 1, or 30 days after the Federal Register notice is published. No further delays are expected. APHIS will only require a Lacey declaration for products in harmonized tariff provision 4415 (wood pallets and containers) that are imported as the new commodity. This will not include products that are used, recycled or reclaimed. Nor will it include loaded pallets or containers. The following HTS codes will require a Lacey declaration at that time: Ch. 33 Headings (Essential Oils) 3301295109-essential oils of cedarwood 3301295121-essential oils of linaloe or bois de... Read More
SECTION 301 – Additional China Duty Status
Arguments, Motions Scheduled for Section 301 Tariff Lawsuit Oral Argument Scheduled. On Thursday, June 17, the U.S. Court of International Trade (CIT) will hold an oral argument on plaintiffs’ motion for a preliminary injunction. The motion seeks to suspend the liquidation on entries involving the Section 301 duties challenged in the court cases. The government filed a memorandum opposing the motion and plaintiffs have asked to court to permit the filing of a reply to that opposition. The government stated it would defer to the court on whether to accept a reply. Because most court precedent supports the fact that an Office of the U.S. Trade Representative (USTR)-directed function, e.g., Section 301 tariffs, where Customs and Border Protection (CBP) performs a ministerial role, e.g., collecting but not deciding whether to collect duties, is not a protestable decision, many practitioners had advised that protests were unnecessary to preserve Section 301 claims. However, recent activity in the case concerning the suspension of liquidation shows that even this threshold issue is not an entirely settled one. Motion for Judgment or Dismissal Filed. On June 1, 2021, the government filed motions to dismiss and alternatively for judgment on the agency Record. The deadline for the response is Aug. 2 and the Section 301 Steering Committee is actively and collaboratively preparing that response. Much of the government’s argument claimed that based upon its discretionary authority,... Read More
FSVP – DUNS NUMBER (“UNK” TO TERMINATE JULY 2022)
UPDATE (JUNE 14TH, 2021) No More ‘UNK’ for FDA Entries in July 2022 The Food and Drug Administration (FDA) told NCBFAA Regulatory Affairs Committee (RAC) members that use of the term “UNK” (representing “unknown”) will not be allowed for food imports in place of a valid DUNS number for in the Unique Facility Identifier field for the FSVP importer, starting July 2022. The agency has already started targeted outreach by sending emails to customs brokers and importers who have used UNK. Use of the UNK was officially allowed as a temporary measure in 2017 when the FSVP requirements were first implemented to give importers time to adjust to the new requirements. The process for obtaining a DUNS number can be lengthy. Customs brokers are encouraged to urge their clients to apply for a DUNS number now through the D & B Website line following: https://www.dnb.com/duns-number.html?utm_medium=email&utm_source=govdelivery The FDA is sending out notifications to advise the importing public who deal with food importations, that the “UNK” option (versus the actual report of a consignee’s DUNS number) is going to soon expire and importers will be required (in the near future) to supply their consignee / importers actual DUNS number within the entry record that your broker uses when transmitting your FDA data to Customs and to the Food & Drug Administration. Please make sure that you work to obtain your DUNS number, or the... Read More
VOIDED IMPORTER OF RECORD TAX (EIN) NUMBER – WHAT TO DO
CBP, since 2019 has taken to VOIDING Importer or Record tax (EIN – Employer Identification Numbers) numbers that are infrequently used on import entries. This means that if you are an infrequent importer (once every 2 years or more) you will probably at some point in time have CBP VOID your tax number in their computer system (ACE). Their void does not remove your number from the Internal Revenue Service records, only from the records of CBP (Customs & Border Protection Services). Previously CBP only VOIDED numbers for the the following reasons (listed below), but have recently taken it upon themselves to just VOID numbers that are NOT used very often. Here is the link for the instructions on VOIDED Importer of Record numbers (their FAQ page) – https://www.cbp.gov/trade/priority-issues/revenue/bonds/voided-importer-record-faqs Commonly CBP reports that they VOID Numbers for these reasons: Importer records may be voided for the following reasons: Duplicate records are on file with CBP The importer’s Social Security number or Employer Identification number cannot be verified with the appropriate government agency (Social Security Administration or Internal Revenue Service respectively) The importer, their authorized agent (with a valid Power-of-Attorney), or local CBP Officer has requested that the record be voided CBP has received returned (undeliverable) mail when attempting to contact the importer via the US Postal Service Failure to respond to CBP requests... Read More
FORECED LABOR – IMPORTER BEWARE
FORCED LABOR: We ask you to take immediate notice of a situation certainly not new, known as “FORCED LABOR”. CBP – U.S. CONGRESS and other NON-GOVERNMENT stakeholders are pushing hard trying to stop the proliferation of the utilization of FORCED LABOR throughout the globe. What has brought this to the forefront is the findings in the Xinjiang region of China where situations have found that FORCED LABOR is being used in the production and harvesting of Cotton. The basic legal provision that outlaws FORCED LABOR is 19USC 1307, where it states that “All goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in any foreign country by convict labor and/or forced labor and/or indentured labor under penal sanctions shall not be entitled to entry at any ports of the USA and importations thereof is hereby prohibited…” The remainder of this notice is short but part of what we want to pass along or advise you of is, that importations of Stevia have been detained and seized by the U.S. Government, with penalty notices issued to the U.S. Importer. Further it has been reported at the port of Blaine, Washington that containers of clothing were refused entry by CBP because it was believed by CBP Officers that the clothing articles were made in whole or in part of Cotton manufactured with forced labor. No proof of any such claim by CBP was necessary in making the CBP their assertion and in the end CBP invoked refusal of the shipments. ... Read More
Security
Welcome – Security
Security at Sanders Brokerage: Welcome, and we hope you enjoy the staff and services of Sanders Brokerage Services. Hopefully by now you know a bit about the background and heritage of Sanders Brokerage Services. We take security personally and hold our government’s security programs with high regard. We have been a proud C-TPAT (Customs Trade […]
USDA
APHIS – LACEY ACT PHASE VI – August 1st, 2021
The following article submission has been provided by the NCBFAA (The National Customs Brokers and Forwarders of America): APHIS Lacey Phase VI Implementation Will Begin Aug. 1 October 1st. NOTE/ UPDATE – Last week, the NCBFAA Regulatory Agencies Committee (RAC) reported that the USDA’s Animal and Plant Health Inspection Service (APHIS) Lacey Phase VI would […]
FDA
FSVP – DUNS NUMBER (“UNK” TO TERMINATE JULY 2022)
UPDATE (JUNE 14TH, 2021) No More ‘UNK’ for FDA Entries in July 2022 The Food and Drug Administration (FDA) told NCBFAA Regulatory Affairs Committee (RAC) members that use of the term “UNK” (representing “unknown”) will not be allowed for food imports in place of a valid DUNS number for in the Unique Facility Identifier field […]
CBP
APHIS – LACEY ACT PHASE VI – August 1st, 2021
The following article submission has been provided by the NCBFAA (The National Customs Brokers and Forwarders of America): APHIS Lacey Phase VI Implementation Will Begin Aug. 1 October 1st. NOTE/ UPDATE – Last week, the NCBFAA Regulatory Agencies Committee (RAC) reported that the USDA’s Animal and Plant Health Inspection Service (APHIS) Lacey Phase VI would […]
