TradeLane

When traveling between the United States and Europe, one of the most startling differences that I observe is the concoctions that we put on our French fries. First of all, we can’t agree whether or not these delicious fried potatoes should be called fries, chips, or “freedom fries.” Once served to us, Americans love their ketchup, continental Europeans love their mayonnaise, and the occasional Brit won’t eat their chips without a particular brand of brown sauce named after Parliament. However, we all can agree that, while bad for you, fried potatoes are delicious. 

The EU and U.S. also mostly agree that international trade is a good thing. Trade stimulates job creation and incentivizes economic growth. Markets are often opened by the implementation of preferential trade agreements between two jurisdictions. The U.S. and EU are currently negotiating the Transatlantic Trade and Investment Partnership (TTIP) to strengthen the ties between the two continents and to stimulate growth. 

Just a quick note to give all of you blanket flaggers and possibly even some of you Entry by Entry flaggers a heads up. Five times in the past three weeks I have been advised by importers that information pulled from ACE does NOT show 100% of their summaries with reconciliation flag (indicator) codes. Some might say that common sense should tell you that as a blanket flagger you should KNOW that all of your imports are being flagged for reconciliation. But, reality is – well, reality! People tasked with preparing reconciliation filings aren’t always “in the know” with respect to their company’s flagging set ups and the first thing they do after pulling a report from ACE is to dump all the summaries that don’t have reconciliation indicator codes.

Importers participating in the Reconciliation Prototype Program (RPP) need to be aware that U.S. Customs and Border Protection recently started reviewing all reconciliation bond riders currently on file. 

A few months back, I posed the question to you, “Do I really need a trade compliance expert?”  The overwhelming response, was that yes, in fact, I (you) do.  However, let’s dive a little deeper into some of the reasons why you need an expert.

How long has the reconciliation program been around? The prototype – yes prototype – will celebrate its’ 16^th birthday this coming October 1^st. So imagine my surprise when I was recently contacted by an importer that had been “kicked out” of the program. Since that phone call several months ago I have been made aware of no less than five importers that have either received the “boot” or been “put on notice.”

Historically Customs and Border Protection (CBP) has put up with importers that are habitually late with their reconciliation filings. Meaning CBP – via FP&F – issues the NO FILE liqudated damages notices, the importer has their filer process and file a reconciliation entry, CBP mitigates the penalty, the importer pays the Option 1 amount, and we repeat the process again next month. Works for everyone involved right? CBP gets a little more money via the Option 1 amount, the importer doesn’t have to increase headcount or reallocate resources, and the recon filer gets more filings this way. These habitually late importers – and they know who they are – seem to have taken the stance that they would rather pay $500.00 each month for late files rather than address the problem.