The Trade Bridge Blog

New from BIS: Export Control Reform Initiative: Strategic Trade Authorization License Exception

http://1.usa.gov/l1oQ7A

On my way to LA today.... to speak about "How to Avoid Hidden Foreign Trade Show Costs Using Carnets."

@ Global California 2011 tomorrow.  http://t.co/TRWu8gM

 

Urge your congressional reps to get your state’s share of a $30,000,000 grant for exporters

http://1.usa.gov/eWkTag & http://bit.ly/f4EfYo

These Export Training Videos on Export Regulations by the U.S. Census Bureau Can Guide Your Goods to Profits Abroad

http://bit.ly/YaXvt

The Last Remaining Export Incentive

http://bit.ly/hqwGvl

“Now is the time to start exporting if you don’t already. As a result of the National Export Initiative new online tools like this one make getting started simple and the Department of Commerce is standing by to take your calls.”

http://bit.ly/bud6mF

Merging the SBA into the Department of Commerce? Great for small business or a big business boondoggle?

http://bit.ly/bMhWw2

Regulatory Purgatory - It's a Maze

Here's a quick reference guide to the tsunami of new regulations that are besieging exporters and importers:

The Lacey Act Amendment - effective approximately April 1st, 2009

Automated Export System Filings - effective June 2nd, 2008

10+2 - Security Filing - pending final ruling

Consumer Product Safety - Effective November 12th, 2008

First Sale Valuation - effective August 20th, 2008

ALERT: Environmentalism Gone Awry, The Lacey Act Amendments

While we are all busily preparing for 10+2, a wolf in sheeps' clothing slipped in through the compliance door on May 22nd, 2008. It is hard to believe how these amendments passed. It could literally bring the commerce of the US to a grinding halt, but, short of WTO intervention, it will be effective on December 15th of this year. Basically, if you import into the US and the imported goods contain or include plant products or are derived from plant products (with few exclusions), you must make a separate declaration at the time of importation. This includes each species that was used and each country from which the plant was taken. The commodities most obviously affected are:

• Lumber,
• Wood pulp,
• Paper & Paperboard, AND
• Live plants if listed under CITES, The Endangered Species Act or other specialized conservation laws, BUT ALSO
• Furniture,
• Umbrellas,
• Resin,
• Cigarettes, AND
• Printed matter,
• Boats, cars, trains, planes,
• Musical instruments,
• Pharmaceuticals,
• Textiles, IN SHORT
• anything containing anything derived from plants (unless excepted).

Originally the Lacey Act was designed to protect animals illegally killed in their state of origin...now, since all the import declarations will have to be done manually for awhile, it is creating a paper nightmare and a complete waste of resources. Well, folks, these are your tax dollars at work!

We Are Making a Difference

I'm jazzed to report that Trade Bridge is making an impact. We are providing the WCO with some very welcome and much needed feedback from our members, U.S. SMEs. I was in Brussels in December speaking to a SAFE conference about SME views on C-TPAT. TBI Chairman Bruce Wilson goes to Brussels next week to attend the 2nd SAFE Working Group meeting. As an Observer, TBI can provide input and the SME perspective at an international level.

The Canadian SME community, through their trade associations, are also interested in providing the Canadian perspective for Trade Bridge to represent to the WCO. This would be a valuable addition to the Trade Bridge cause which I will be pursuing in the coming months.

Keep your fingers crossed as CBP reviews my application to COAC. If I am appointed, Trade Bridge and its 7000 SME importer-exporter members, will have a direct line of communication to Congress. Is there any question that this is a movement whose time has come?

10 + 2 Becoming a Reality - Get Prepared

10 + 2 is bearing down on us. The rule is now a Notice of Proposed Rule Making (NPRM) and in less than 60 days it is likely to be inevitable. For information on how to prepare your company for this change see Customs web site, the American Association of Exporters and Importers Alert, Trade Innovations' write-up, and any of the Trade Bridge International FAQs on 10+2: October 18th, 2007 webinar, June 7th, 2008 webinar. If you are considering direct-filing of your customs entries with TRG Direct you may automatically be prepared to comply with this new security rule. Contact the direct-filing experts for details.

Trade Bridge at the World Customs Organization

Next week Trade Bridge makes its debut at the WCO in Brussels. I'll be presenting an update on C-TPAT from the perspective of SMEs. Thanks to all of you who completed the survey. Your views will be made known at the WCO SAFE Framework of Standards conference on December 11th. Check www.TradeBridgeInternational.com for the results of the C-TPAT Survey.

What is 10? What is 2? What is 24?

Here are the 10 advance data elements to be required by "10+2" from the responsible party, the importer:

1. Manufacturer name and address
2. Seller name and address
3. Container stuffing location
4. Consolidator name and address 
5. Buyer name and address 
6. Ship to name and address   
7. Importer of record number   
8. Consignee number   
9. Country of origin of the goods   
10. Commodity Harmonized Tariff Schedule number (6 digit)

Here are the 2 additional advance data elements to be required by "10+2" from ocean carriers:

1. Vessel Stow Plan
2. Container Status Messages

Expect to have to produce this info 24 hours before the vessel is loaded.

10+2 Redux, featuring John Jurgutis, CBP

Trade Bridge members met with CBP this month courtesy of TBI, to hear about CBP's Security Filing (10+2). Members met in the San Francisco Bay area with John Jurgutis, a Management and Program Analyst for the Secure Freight Initiative. The seminar was simultaneously broadcast to a TBI SME webinar audience. Over 200 SME participants were engaged in finding out what CBP's latest Security Filing (10+2) means for them and their business operations. (The WCO also addressed the audience from Brussels but I'll discuss that topic in a later post.) This effort by CBP to talk directly to SMEs is part of their response to demands from the trade that "CBP needs to reach out and get our feedback." If you're interested in seeing the program materials check out this TBI page. Feedback to CBP can be sent to John Jurgutis.

SBA Trade Programs Act Approved by Committee - Sometimes I Feel So Republican

Sometimes I feel so Republican. (You know, "keep taxes low to stimulate the economy" vs. "increase taxes to pay for programs to stimulate the economy.")

Call me "old-fashioned" but I would like to know that taxpayers' hard earned dollars are actually funding something worthwhile. And that's why I can't quite decide whether I like this amendment to the Small Business Act or not.

The House Small Business Committee just approved an amendment to the Small Business Act that appears to be a big coup for future and beginner SME exporters: "SBA Trade Programs Act of 2007 - To amend the Small Business Act to improve trade programs, and for other purposes." It covers the gamut of govenmental support from finance to trade protection. The intent of expanding U.S. exports via the SME exporter is laudable. I'm just not convinced this is the way to do it.

The amendment will cost taxpayers money to implement and maintain. Will the cost be worth the return to our economy? What is the expected return to our economy? None of this information appears in the amendment so it's impossible to make an informed decision about whether or not to support the amendment.

As an advocate for SME exporters it seems like a slam dunk for Trade Bridge to come out in favor of this amendment. It does, after all, appear to provide significant help to SMEs that want to expand into global markets. But is it prudent to support the amendment on what may simply be, a noble goal? If monies are appropriated (which the amendment calls for) and the amendment doesn't do anything to either improve the export capabilities of SMEs or the U.S. economy it will be wasted time, effort and money.

I'm wary of the government's ability to design and implement these changes effectively and efficiently when the accountability seems either nonexistent or an afterthought. (Again, call me "old-fashioned.")

For now though, I'm keeping an open mind while I conduct more research. Check back here regularly as I will continue to update and post information as I get it.