Import Practices March 10 Dhl

Import Practices

Wednesday March 10, 2010

Presenter: Darie Achstein-Conway

Mgr, Global Trade and Compliance

Imports Questions: Are your imports in order?

• What are you importing?

• Is Senior Management involved?

• Who within your company is handling your imports?

• Is the companies Customs Bond up to date?

• What company holds your Custom Bond?

• Does your company have an import manual?

• Who are your brokers? Do your brokers have a company SOP?

• Is your company using the brokers portal for data access and reports?

• Does your company have up to date POA’s with brokers?

• Is your company CTPAT?

• Does your company use ACE? http://www.cbp.gov/xp/cgov/trade/automated/modernization/

• How is your companies record keeping?

• Does/do the import team attend seminars? Are they keeping up to date on changes in trade?

• Who handles company classification?

• Does your company audit the internal import process?

• Does your company have to add an assist?

• Has your company checked their ITRAC? http://www.cbp.gov/xp/cgov/admin/fl/foia/itrac/itrac.xml

• Does your company do pre and post audits?

Import Compliance Department

Depts Involved with Imports

ImportComplianceDepartment

Purchasing

Accounting

Export ShippingReceivingInventory

Research &Development

Engineering

Legal

MIS

Internal Audit

Service Provider

Customs Records

EntryLine Items

Product/ArticleCommercial Invoices/Purchase

OrdersAccounting Transactions

General LedgerFinancial Statements

Tax Return

Importer's RecordsCBP related account activity to financial statements and trial balance to verify completeness Accounting Records

LC, Payables, Etc.

Entry SummaryEntry Package

Audit Trail - Entry Documents

5

INVOICESOLD TO: HAM RADIO INC. INVOICE NUMBER: 3REC4456

ADDRESS: 12345 RADIO DRIVE DATE: NOV 8, 1998

RADIO CITY, NV 45678

P/O-NO: 49903

FROM: TOKYO, JAPAN TO: LOS ANGELES PER: MONARCH RULER

MARKS & NOS DESCRIPTION OF GOODS QUANTITY

UNIT PRICE

(US$)

AMOUNT

(US$)

C/NO. 1- 6 (@ 20) B54729-P-555

B04500005 DR R.F. DECK 99CH 2500 SETS 252.00 630000.00

DOCUMENTS MATCH

Commercial Invoice Requirements

• Seller name & address - 10 + 2 requirement

• Buyer name & address - 10 + 2 requirement

• Date of shipment

• Shipper’s name

• Receiver or consignee’s name

• A detailed description of the merchandise

• Shipping and packaging marks (also can be put onto a packing list)

• Quantities in weights and measures (also can be put onto a packing list)

• Country of Origin/Manufacturer - 10 + 2 requirement

• HTS Classification - 10 + 2 requirement

• Value of the merchandise

• Unit and total purchase price

• Currency of the sale

• Terms of Sale (DDU, DDP, ExWorks, CIF)

• Ensure that the invoice is in English

Broker SOP (Standard Operating

Procedures) and establishing a relationship

• How did your company choose their Broker?

• Does your company have a POA with the chosen Broker?

• Does your company have any special import instructions to share?

• Does your company have any added assist?

• Supply the Broker with company HTS, OGA (FCC, FDA, etc.)and COO for company product.

• Who is the company internal contact and their back up for the Broker?

• Does your company have an open communication with the Broker?

• Does your company have a quarterly review with the Broker?

• Is your Broker keeping your import team updated with changes?

• Is your company keeping your Broker updated with changes?

• How is your Broker’s recordkeeping process? Do they send your company back up paperwork for your company recordkeeping?

Power of Attorney – POA

7501 - Entry Summary

What is an Assist?

What is an “Assist”?

An “assist” is any of the items listed below that the buyer of imported merchandise

provides directly or indirectly, free of charge or at a reduced cost, for use in the

production or sale or merchandise for export to the United States.

•Materials, components, parts and similar items incorporated in the imported merchandise

•Tools, dies, molds and similar items used in producing the imported merchandise

•Engineering, development, artwork, design work, and plans and sketches that are

undertaken outside the U.S. and are necessary for the production of the imported

merchandise.

“Engineering, development, etc” will not be treated as an “assist” if the service work is:

1.Performed by a person domiciled within the U.S.

2.Performed while that person is acting as an employee or agent of the buyer of the

imported merchandise, and

3.Incidental to other engineering, development, artwork, design work, or plans or sketches

undertaken within the U.S.

Value of an Assist

How is the value of an “Assist”determined?

In determining the value of an “assist”, the following rules apply:

1.The value is either

a)The cost of acquiring the “assist”, if acquired by the importer from an unrelated seller, or

b)The cost of producing the “assist”, if produced by the importer or a person related to the importer.

2.The value includes the cost of transporting the assist to the place of production.

3.The value of “assists” used in producing the imported merchandise is adjusted to reflect use, repairs, modifications, or other factors affecting the value of the “assists”. “Assists” of this type include such items as tools, dies, and molds.

Hardware Commercial Invoice (CI) for

International Travel

Guidelines for the Hardware CI:

• Keep the CI in the laptop bag

• The CI are only to be given to Customs if the electronics are searched

• Keep a soft copy on the desktop

• Have a business card or employee badge present and passport, this will tie the employee to the CI and to the company

Frequently Asked Questions on Imports?

• With the stressed economic times, how do I sell the need for imports (compliance) to my company?

• How do I sell compliance to Senior Mgmt?

• What is an HTS? http://www.usitc.gov/tata/hts/bychapter/index.htm

• Why is a Country of Origin required?

• Where do you find those with import knowledge to hire?

• How do I incorporate the other departments in my company?

• Why do companies consider the import function expandable?

• How does my company find a Broker?

• How much should my company rely on a Broker?

• Should I do training with the internal company staff?

• Does my company need to hire an import person/persons with years of experience?

• How does the company import person stay updated?

Current and Upcoming Import

Programs

• 10 + 2, ISF

• Lacey Act

• Mandates for Cargo Screening

• Modernization Act

Informational Websites for Imports

• Port of Long Beach - www.polb.com

• Port of LA - www.portoflosangeles.org

• Dept of Homeland Security - www.dhs.gov

• Customs Border Protection - www.cbp.gov

• TSA - www.tsa.gov

Professional Organizations

• www.icpainc.org

• www.ftasc.org

• www.aaei.org

• www.wiit.org

• LinkedIn (free, join import and compliance LinkedIn groups)

Questions

Contact Information

• Darie Achstein-Conway

• Cell: 949.874.4119

• [email protected]

• LinkedIn participant