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FSVP – DUNS NUMBER (“UNK” ON THE WAY OUT)

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 DUNS number of your “ship to consignee / buyer” in the U.S.A. We have attached a copy of the letter currently being distributed by the FDA as an advance advice notice to importers and non-resident importers. FSVP and DUNS requirement UNKN notification letter  Read More

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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

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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

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Section 301 China Exclusions – Cautionary Warning

As most will recall, the U.S.A., has been involved in a very large trade war with China under the Section 301 provisions of our regulations, amounting in additional Tariffs, from 7.5% up to and including 25% (additional duty’s).  A large number of “EXCLUSIONS” were issued throughout the years, some as resent as September of 2020 reduced these additional duties.  We caution all importers and ask that you be aware that many, and most likely all, of those exclusions (which granted lower or no additional duties) are set to expire on December 31, 2020.  Should these exclusions expire on December 31, 2020 it is our conjecture that the Section 301 duties could revert back to 25%.  Again, this is only our opinion, but returning to 25% additional duties is exactly what happened in August of 2020 when certain other exclusions expired.  The United States Trade Representatives (USTR) in September reinstated those exclusions through December 31, 2020 making them retroactive to August 7th, 2020, however, importers (through their broker) had to request Post Summary Corrections (PSC) or protest entries refund duty money’s paid in excess.   It will be very hard to predict what the United States Trade Representatives will be instructed to do in the remaining months of the current Presidents Administrative authority.  Additionally, there is no way to know, read or guestimate as to what the President Elects’ opinion will be on the Section 301 China tariffs... Read More

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PREPARING FOR THE 2020 BIENNIAL REGISTRATION RENEWAL

The announcement below is for our FDA clients who have an FDA Registration Number.   Preparing for the 2020 Biennial Registration Renewal In preparation for the 2020 Biennial Registration Renewal period, we have a few tips: Ensure that your FURLS account is up to date with a valid password Please visit https://www.access.fda.gov/ to access your account. If you have forgotten your Account ID and/or password, please select ‘Forgot Account ID’ and/or ‘Forgot Password’ to obtain your login information. If you have not accessed your account in over 90 days, you will be required to create a new password. Please visit https://www.fda.gov/food/online-registration-food-facilities/fda-industry-systems-account-management-guide for more information on managing your account or resetting your password. If you require further assistance, please call our FURLS Helpdesk at 1-800-216-7331 or 240-247-8804 or email FURLS@fda.gov. Due to the high call and email volume received during the renewal period, we encourage you to contact us in advance of the renewal period for account management assistance.   Obtain or verify your facility unique facility identifier (UFI) In accordance with 21 CFR 1.232(a)(2), beginning October 1, 2020, the facility’s UFI recognized as acceptable by FDA will be required to be submitted with the registration information. At this time, FDA recognizes the Data Universal Numbering System D-U-N-S (DUNS) number as an acceptable UFI. DUNS numbers are assigned... Read More

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USMCA – U.S.-Mexico-Canada Agreement

Taking effect on July 1, 2020 is the USMCA (United States-Mexico-Canada) Agreement.  There are some subtle changes and some not so subtle.  Some of the biggest changes are the fact that there is no specific form mandated.  But instead of reinventing the wheel through our own written interpretations, we will paste the following exert from U.S. Customs (CBP) in their “Interim Implementing Instructions”. Certification or Other Document Requirements: An importer may submit an importer, exporter or producer certification. The importer is responsible for exercising reasonable care concerning the accuracy of all documentation submitted to CBP. The importer may make a claim for preferential tariff treatment based on a certification of origin completed by the importer, the exporter or the producer, for the purpose of certifying that a good qualifies as an originating good. If an exporter that is not the producer of the good certifies the origin of the good, the certification may be completed by the exporter on the basis of either: (1) having information, including documents, that demonstrate that a good is originating; or (2) reasonable reliance on the producer’s written representation that the good is originating. If a producer or an importer certifies the origin of the good, the producer or importer must have information, including documents that demonstrate that the good is originating. The certification need not be in a prescribed format; it may be provided on an invoice... Read More

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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 […]

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USDA

Wood Packing Material

THE U.S.D.A., SAY, Make sure your wood packing material has been properly heat or methyl bromide treated!   U.S.D.A. is refusing shipments that contain pallets and wood packing material that is not properly marked are treated with ISPM 15 or IPPC logos.  Make sure your shipment is admissible and become familiar with the information on the […]

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FDA

FSVP – DUNS NUMBER (“UNK” ON THE WAY OUT)

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 […]

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CBP

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 […]