TradeLane

The last several years have shown a spotlight across organizations on the importance of investing in and maintaining a sound trade compliance program. From additional tariffs on Chinese-origin products, to ever-expanding sanctions resulting from the conflict between Russia and Ukraine, to regulatory and procedural changes worldwide, companies continue to invest in their compliance operations to manage their risk and pursue duty savings opportunities.

The Regional Comprehensive Economic Partnership (“RCEP”) was signed on 15 November 2020 and entered into force on 1 January 2022 for ten countries: Australia, New Zealand, Brunei Darussalam, Cambodia, China*, Japan, Laos, Singapore, Thailand and Vietnam. It was subsequently entered into force for the Republic of Korea on 1 February 2022 and Malaysia on 18 March 2022, and most recently ratified by Indonesia on 30 August 2022. RCEP is one of the largest free trade agreements (“FTA”), covering around one-third of the world’s population and accounting for about one-third of global GDP.

*Note that Hong Kong, China (“Hong Kong”) is a separate customs territory from the People’s Republic of China (“China”).

As with most questions in the Trade Compliance space, the answer to this question can be nuanced and significantly impact an importer’s compliance risk, and the landed cost of the goods.

Importers who use Foreign Trade Zone (FTZ) sites to store regulated hydrofluorocarbons (HFCs) may be interested to learn the EPA has clarified that HFCs will be treated the same whether the cargo is entering/exiting an FTZ or if a consumption entry is being filed.^[1] The HFC Phasedown went into effect November 2021.

Recently, I had to provide someone with a list of the top ten CTPAT Minimum Security Criteria that I thought were the most critical. This was not an easy exercise. As any importer who is a CTPAT member knows, there are 140 different criteria, and each one is important, especially the required ones.