TradeLane

Accuracy of your HTS classifications is as important as ever.  Have you reviewed your current classification database? Are you aware there could be fines and penalties for incorrect tariff codes.  Coming up, Tradewin will have a two part blog series outlining the importance of accuracy, but first, a reminder of why it is so important!

HTS Classification is a necessary evil. Unfortunately, it is an evil that must be revisited often. There are various ways to approach harmonized tariff classification from doing it yourself, hiring a third party service provider, or just putting the pages up on the wall and throwing darts at it to determine which HTS Classification to use. (While the last one is a great way to relieve the stress of classification, I personally would not recommend this method).

You may have missed it but on February 24, 2016, H.R. 644 became public law. What is H.R. 644 you ask? It is the Trade Facilitation and Trade Enforcement Act of 2015.

Great. More rules. And largely with a focus on CBP, ICE and the GAO. Snooze.

But for importers there really is some awesome news!

Put a band aid on it, it will be ok. Walk it off, you’re not really hurt and you’re holding up the game.

As a guy who has played hockey most of my life I have heard this many times. Then you wake up the next morning take a look and think “Hmm… That might need stitches”.  Sometimes trade programs do not look as good as you thought, too.

Over the years, I have talked to many importers and exporters about the state of their trade programs. Most listen with great interest and agree that their trade program does not get the attention it deserves. I usually ask one simple question: How much of your business relies on trade?

Then there are the excuses for not paying attention to the international movement of your goods. When I was in school, I had plenty of excuses and now in my career I have hear lots of them.

I will be safely flying to Seattle tonight. From Charleston, SC to Boston and then on to Seattle. I listened to the Governor of South Carolina talk about assessing the ongoing risk and damage to the environment, to assets and to people’s lives. There are currently more than 500 roads closed in South Carolina. A cascade of dams are being breached. As my wife, Liz was driving us through the 18” of water on the road we were looking around at the carnage and it got me thinking about how this risk might have been assessed and mitigated earlier versus just assessing and repairing the damage after the fact.

In a similar manner, unidentified risks can lead to unexpected damage to your company. Experience tells us that it often starts with a single-issue request for information (CF28) from Customs and Border Protection and cascades like those dams, where each failure swiftly leads to the uncovering of others. I am sure that you have seen this. One classification inquiry leads to a second, and a third and then a request for a sample, and documents confirming transaction value. Then what about those free trade claims? It is very difficult to stop the process once it starts.

In 1519 Ferdinand Magellan set sail on an expedition to be the first person to successfully cross the Pacific Ocean. Relying heavily on the navigational technology of his time he would have depended upon instruments such as hour glasses, palnispheres, quadrants and compasses, all of which would have been considered high technology.