Published February 28, 2013 by

Comparative Perspective on Census Generous Offer: Free Trade Data on Exports

Census Bureau is making a “generous” offer to members of the U.S. export trade community: 12 months of data free of charge every 365 days.  All one needs to do is submit two documents: (1) Request Letter and (2) Certification of Authority. Request letter should contain the following four (4) elements: Reason for request (i.e. internal company audit); EIN(s) and names of the requesting company and all subsidiaries, affiliates, or business units. Indication of whether your company is a United States Principal Party in Interest (USPPI) or the Authorized Agent (see Foreign Trade Regulations section 30.1 and 30.6(b)(1)); Contact Information: Name, Address, Phone Number, Fax Number, and Email Address. Certification of Authority is pro forma statement affirming one’s entitlement to request. The offer is “generous” when compared to obtaining the similarly situated data for its imports from Census’ sister federal agency – Customs and Border Protection (CBP).  CBP requests for import data are dealt under FOIA rubric of Importer Trade Activity requests (ITRAC).  Unlike Census, CBP charges “$250.00 – $300.00.”  But, the depending on how far back one wishes to go, the cost may be justified because ITRAC requests entitle one to five (5) years worth of data.  The 5…

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U.S. Federal Agencies

Census Bureau Customs and Border Protection Department of Commerce Freedom of Information Act

Published January 9, 2012 by

Licensed Customs Broker without a Permit: Engaging in Customs Related Advice

This article explores the limits of when a licensed customs broker, who does not hold a permit from a Customs port director, may render an international trade advice (“customs business” advice) as a consultant or an independent contractor.  This question relates to many talented trade professionals who got displaced from their small and medium sized businesses due to a general customhouse sector trend toward consolidation under the umbrella of a large corporate logistics enterprise.  Many of these professionals continue to maintain their customs broker licenses, but do not maintain a port or a national permit. A licensed customs broker working for a large corporation may wish to engage in independent consulting work as a way to generate some extra income (hopefully without running afoul with the non-compete provisions of its large corporate employer).  Also, there are those folks who have been affected by corporate reductions and look for ways to generate some consulting revenue.  Since this article is written with licensed customs brokers in mind, it does not pertain to other issues, such as referrals under 19 C.F.R. §111.36. To understand the threshold of a “licensed” activity, regulations provide a good starting point.  Regulations state that unless you are an…

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U.S. Federal Agencies U.S. Federal Courts

Bureau of Industry and Security Census Bureau Customs and Border Protection Directorate of Defense Trade Controls

Published April 18, 2010 by

Schedule B Search Engine

Foreign Trade Division rolled out a new search engine, designed and supported by 3CE, a private software company.   Trade Division, however, does a poor job of reconciliation of 3CE’s search engine with general rules of interpretation, which should be dispositive in determination of harmonized code (Schedule B included).  3CE engine produces false positives, even for simple products.  If one, for example, would try to determine Schedule B number for steel cable ties, 3CE search engine would direct to 7302.90 (Railway or tramway track construction material of iron or steel, the following: rails, check-rails and rack rails, switch blades, crossing frogs, point rods and other crossing pieces, sleepers (cross-ties), fish-plates, chairs, chair wedges, sole plates (base plates), rail clips, bedplates, ties and other material specialized for jointing or fixing rails: Other).  Steel cable ties should be classified in the residual category of that chapter (7326).  Another example are o-rings.  3CE gives you a choice to classify it as an “article for technical use” or as a “part.”  No guidance on either definition is provided.  Therefore, if I choose part, I will land somewhere in the landscape of Section XVI, without even knowing about Note 2 requirements of that section. Trade Division…

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U.S. Federal Agencies

Census Bureau Harmonized Tariff Schedule Classification Schedule B

Published February 18, 2009 by

Exports to International Waters (vessels, buoys, offshore iinstallations)

I highly reccomend to review news posted by Douglas N. Jacobson. Yersterday, Mr. Jacobson recited Census Bureau memorandum called FTR Letter No. 3. Several issues worth noting and for some of us revisiting. First, the AES filers must utilize new “IW” export information code. Second, if one exports BIS licensed commodity, filer must use country of destination and ultimate consignee as indicated on that license. Third, if one exports non-BIS licensed commodity, then filer must use “nationality of the person(s) or entity assuming control of the item(s).” Lastly, AES filers are to report only those commodities that are valued over $2500 / Shedule B and/or those commodities that are subject to license (regardless of value).

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U.S. Federal Agencies

Automated Export System Bureau of Industry and Security Census Bureau Oil & Gas Products