Compliance Circular: August 2019 - CBP Trade Symposium

Compliance Circular: August 2019

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Over 1,200 members of the trade community including importers, exporters, customs brokers, forwarders, carriers and various supporting businesses descended on Chicago July 22-24, 2019 to hear from the top leadership of the U.S. Customs and Border Protection (CBP) service. Speakers at the CBP Trade Symposium included Mark Morgan (Acting Commissioner of CBP), Kevin McAleenan (Acting Secretary of DHS) and Brenda Smith (EAC from the Office of Trade). Also in attendance were speakers from CBP, FDA, DOC and USTR.

Subjects discussed included the Northern Triangle (Guatemala, Honduras, El Salvador) and the Flow of Irregular Migration to the Southern Border, Trade Remedies and the Exclusion process for S232 and S301 tariffs, 21st Century Customs Framework and eCommerce challenges and opportunities.

Some key points from the Symposium:

  1. Southern Border: Safety and security at the Southern Border is and will continue to be a primary focus of CBP for the foreseeable future. The wait time at the border will continue to be challenged while the number of immigrants tax the system. Per Mark Morgan, many human smugglers are taking thousands of dollars from families to get them across the border, yet have no concern for the family or their well-being. Children are being used by multiple migrants to gain access, often recycling the same children over and over. Between the months of October 2018 and June 2019, 780,633 people have attempted to cross the Southern Border, many using the request for Asylum.
  2. S301 Exclusions: A new portal was introduced in June 2019 to expedite and streamline the S301 Exclusion process. In July, the first decision was rendered from exclusion requests submitted in the portal. The turnaround in decisions is expected to improve drastically using this portal. Trade has until August 9, 2019 to provide feedback to Customs/DOC on the portal.
  3. Up and Coming Technology: Three big changes are coming down the pipeline – block chain technology, 3D printing and cryptocurrency.
  4. Modernization of CBP: Some customs regulations have been in place since 1789. With new technology, there are new risks, new opportunities and new responsibilities that require modernization of the regulations and policies.
  5. New Entry Type: Entry Type 86 is being called the “skinny entry” due to the limited information requirements needed to clear the entries for S321 valued goods. The S321 Data Pilot will begin on August 22, 2019 and run for one year. The goal of the new entry type is to provide faster clearance process for those who participate by filing an entry, which provides necessary PGA/Customs data over those importers who do not.
  6. Export Modernization Process:  There is a need to get away from paper and move toward electronic data. Many concerns on the export side include Drawback, Truck Export Manifest and AES penalties. This process to update exports will take a considerable amount of time. A working group is looking at the details of this update.
  7. Countering Illicit Trade: Importers must be providing Due Diligence on foreign suppliers, ensuring that suppliers have been vetted before entering a business agreement. Illicit traffic is driven by the desire for higher profits.  Thus, any weakness that is found in the supply chain becomes the conduit for theft, counterfeiting and pirating.  Importers must have a mindset from the top down to look for these weaknesses and do what they can to prohibit the bad actors from capitalizing on them.
  8. Forced Labor: There are an estimated 25 million victims of Forced Labor around the world. The Consumer Goods Forum works diligently to ensure that all workers around the world should have Freedom of Movement and should not be paying for a job or have to become indebted or coerced to work. Importers must develop a relationship with their vendors to look for ways to combat this problem and eliminate forced labor behavior. ILAB Sweat and Toil, a useful app created by the Department of Labor, helps provide information such as commodity, country and the offenders who might use Forced Labor, Child Labor or Forced Child Labor. If a product or country that is used in an importer’s supply chain pops up on this app, it is imperative that the importer does further screening of the vendor to ensure that they are not guilty of this violation.

Customs renewed its commitment to partner with the Trade through various working groups, including COAC, to use the feedback and comments from the trade community to further improve the process and increase the security for all parties involved in the international trade arena.

Please reach out to Ascent’s Compliance Department for further details at [email protected].

Visit the CBP website for additional information posted about the 2019 Trade Symposium.


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