| Date post: | 29-Jan-2018 |
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[email protected]+1 (416) 510-8800 1
Managing Customs & PGAsA Total Perspective for Importers
Edward (Ned) BlinickChief Product Officer
A Q&A with Gregg Cummings,
Managing Partner, Strix LLC
2
About Gregg
Gregg has more than 25 years of experience in the International trade industry and
Corporate Finance. He is a Managing Partner of STRIX, LLC a leading company in Self-
Filing Software, International Freight, Domestic Trucking and Logistics. He is also the
President of TBI Brokers, Inc., the firm's Customhouse Brokerage.
Gregg is recognized as an expert in the area of customs automation for ISF and Entry filing
and provides important consulting services to companies who seek to bring processes in
house as well as marrying full service brokerage automation and hybrid solutions. He is an
active member of the International Compliance Professionals Association (ICPA) and speaks
frequently on the topics of how importers can streamline their import processes via
automation and internal control.
AGENDA
WONDERFUL WORLD OF ACEChanges, challenges, Opportunities
PGA’s complex challengesGaining Competitive Advantages
TRADITIONAL ROLES OF CBP, IMPORTER, BROKERHistorically and Today
Flexibility and Control of Data
IMPORTER CASE STUDIESBroker’s point of view
Importers point of view
THE ROAD AHEADBest practices
Current regulatory environment
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Unique position in marketplace
Full Service Customs Broker
Cloud based Self-Filing Solution
Formerly
5
•The ACE environment forever changes the
relationship between CBP and the Importer
•This is a positive and needed direction
•Single Window makes sense for today’s technology
PrePost
6
•Changes mean Challenges
•Challenges mean Opportunities
•Opportunities mean Competitive Advantages
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What are the Main Changes
Entry Summary
Cargo Release
PGA’s
CEE’s
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The Main Challenges
•ACE Entry Summary
•ACE Cargo Release
•ACE System Downtime
•ACE System Message sets
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PGA’s remain the Complex Challenge of ACE
FDA
APHIS
DOT
EPA
10
Opportunities begin by exploring the Traditional
Roles between CBP, the Importer and the Broker
Complex challenges always provide Opportunities
11
CBP Roles and Responsibilities
Complex challenges always provide
Opportunities
Then:
US Customs
Reported to Treasury
Collect Duties and Fees
Enforcement
Collect Trade Data, Census
information
Now:
Homeland Security
Security,
Enforcement
Pendulum Swing back to
more traditional
enforcement
Complex challenges always provide Opportunities
Customs Broker’s Roles and Responsibilities
Then
• Primary interface between Importer and Customs
• Oversight of Import Clearance
• Collate Documentation
• Classify goods
• Communicate to Ports
• Full Service
Now
• Not Necessarily primary interface with Customs
• Tougher legal and Regulatory Environment
• Greater push/pull for Importer to Classify
• Greater push/pull for Importer to Collate Docs
Traditional Roles of Importer
Complex challenges always provide Opportunities
Then
• Relied on Broker to provide Service Interface
with Customs
• Process a Mystery
• Visibility Limited
• Penalties for non-Compliance High
Now
• Today’s Technological and Legal
Environment
• Process a Mystery no longer
• ACE Portal
• Importer provides most documentation
• Importer classifies goods
• Must audit ISF and Entry files
• Visibility on par with Broker
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Are you in Control or Out of Control?
Today’s Importer has greater Flexibility and
Options than ever before
Lower Pricing for Brokerage
Options to Self-File
Options to Hybrid File
Automation
Automate Self-Filing
Automate Brokerage
15
It’s The Data Stupid!
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Controlling the Process begins by Controlling
the Data
Importer Case Studies
How does a Broker do this?
How can and should an Importer do this?
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MAIN POINTS
Top places to control import data
• Parts List
• PGA Documentation
• Invoices/Line Items
• Duties, Taxes, Exam/Port Fees
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IMPORTER 1 PROFILE NO PGA
100-5000 ENTRIES, AIR/MOST OCEAN
BROKER APPROACH
• Will Price Competitively
• Parts Lists – Accuracy and Time
Efficiency
• Template ISF and Entry Lanes
• Manage Invoice/Line Items
• Easiest to Automate
• Pay Duties, Exam/Port fees
IMPORTER
• Establish ACH PUN, PMS
• Create/Control Parts List
• Control Invoice/Line Item data
• Easiest to Automate
• Leverage Brokerage Pricing
• Filing Options
• Self-File
• Hybrid File
19
IMPORTER 2 PROFILE NO PGA
100-5000 ENTRIES, AIR/OCEAN/N. Border
BROKER APPROACH
• Will Price Competitively
• Parts Lists – Accuracy and Time
Efficiency
• Template ISF and Entry Lanes
• Manage Invoice/Line Items
• Pay Duties, Exam/Port fees
IMPORTER
• Establish ACH PUN, PMS
• Create/Control Parts List
• Control Invoice/Line Item data
• Leverage Brokerage Pricing
• Filing Options
• Self-File
• Hybrid File
20
IMPORTER 3 PROFILE PGA
100-2000 ENTRIES, AIR/MOST OCEAN
BROKER APPROACH
• Can Price Competitively
• Parts Lists – Include PGA data
• Table or Spreadsheet PGA Data
• Template ISF and Entry Lanes
• Automate System above 800 Entries
• Pay Duties, Exam/Port fees
IMPORTER
• Establish ACH PUN, PMS
• Create/Control Parts List
• Understand and Include PGA data
• Leverage Brokerage Pricing
• Filing Options
• Self-File
• Automate Self-Filing, Hybrid
File
• Hybrid File
21
IMPORTER 4 PROFILE PGA
2000+ ENTRIES, AIR/MOST OCEAN
BROKER APPROACH
• Less Pressure to Price Competitively
• Parts Lists – Include PGA data
• Table or Spreadsheet PGA Data
• Template ISF and Entry Lanes
• Automate System Creates Huge Cost
Savings
• Pay Duties, Exam/Port fees
IMPORTER
• Establish ACH PUN, PMS
• Create/Control Parts List
• Understand and Include PGA data
• Leverage Brokerage Pricing
• Filing Options
• Self-File
• Automate Self-Filing, Hybrid
File
• Hybrid File
22
IMPORTER 5 PROFILE PGA
100-5000+ ENTRIES, AIR/ OCEAN/N. Border
BROKER APPROACH
• Less Pressure to Price Competitively
• Parts Lists – Include PGA data
• Table or Spreadsheet PGA Data
• Template ISF and Entry Lanes
• Automate System Creates Huge Cost
Savings
• Pay Duties, Exam/Port fees
IMPORTER
• Establish ACH PUN, PMS
• Create/Control Parts List
• Understand and Include PGA data
• Leverage Brokerage Pricing
• Filing Options
• Self-File
• Automate Self-Filing, Hybrid
File
• Hybrid File
23
THE ROAD AHEAD
Common Themes and Best Practices
24
THE ROAD AHEAD
Common Themes and Best Practices
MAIN POINTS to control import data
PARTS LIST • Individual Part Numbers
• Associate Number to HTS, CO, MID, PGA, FTA, GSP
PGA DOCUMENTATIONAdd to Parts List
• Template or Spreadsheet PGA Documentation
• Immediate updating as new Suppliers are Added
INVOICES, LINE ITEMS• Purchase Orders
• Implement a Standardized Invoice
• Part Numbers for all Invoices/Line Items
DUTIES, TAXES, EXAM/PORT FEES•Establish your own ACH PUN
•Apply for PMS
•Easy to get Broker to Pay
25
THE ROAD AHEAD
Common Themes and Best Practices
TAKE CONTROL WHERE YOU CAN
LEVERAGE BROKERAGE PRICING
EXPLORE AND UTILIZE SELF OR HYBRID FILING
• Self-File ISF/Entry
• Outsource Entry
• Self-File Some Entries
• Outsource Complex Lanes
• Automate ISF/Entry Data to Self-File
• Automate ISF/Entry Data to Full Service Broker
26
THE ROAD AHEAD
Common Themes and Best Practices
CUSTOMS COMPLIANCE, EXAMS, FINES/PENALTIES
IMPORTER SECURITY FILING• Control at the Port Level
• 6 Month Compliance Tail
• 2O Hold, No ISF on File if within port limits
• Still very manual to have hold removed
• Reduce your Customs Demerits
• To Date, very few fines
• Customs Does Not See your Data Screen
EXAMS• CBP moving back toward Enforcement
• Expect Higher level of Exams
FINES PENALTIES, ADD/CVD• ADD/CVD Cases
• Cold Rolled Steel, Aluminum, Wheels
• CF 28 Same
• CF 29 Same
27
THE ROAD AHEAD
Common Themes and Best Practices
EMBRACE THE SINGLE WINDOW
ROLLOUT WILL CONTINUE TO HAVE BUMPS
BUGS WILL CONTINUE TO OCCUR
AGENCIES WILL CONTINUE TO BE ADDED
28
[email protected]+1 (416) 510-8800 29
Managing Customs & PGAsA Total Perspective for Importers
Gregg Cummings, [email protected]
Edward (Ned) BlinickChief Product Officer
