Held on consecutive weekends, the National Customs Brokers and Forwarders Association (NCBFAA) annual conference and the CNS Partnership Conference offered two opportunities to learn about the current issues that are impacting our company as well as our importer and exporter clients. Below are several of the key takeaways.
Cybersecurity and Export Controls
The issue of cybersecurity is one that every company should be aware of and have both insurance and a disaster recovery plan in place if a breach occurs. An attorney said that fully sixty percent of small businesses fail within six months after a breach. CTPAT membership requirements are going to include a cybersecurity component – so companies in the program or who are contemplating membership need to be ready.
A speaker also gave the audience a reminder that U.S. companies who are involved in technical projects or sell controlled items should be aware of how the items are described online and what, if any, technical specifications or schematics are public knowledge. Information about a controlled item could be considered a deemed export if online and at least one CTPAT member is currently dealing with a potential export penalty.
Valuation and Reconciliation
If the entered value at the time of importation cannot be definitively stated, a reconciliation entry should be used. While reconciliation can be used for issues of valuation, it cannot be used to change classification post-entry because the HTS is one of the key data elements for determining admissibility and release. Check out CBP’s ACE page on reconciliation here.
ACAS is Coming
The Air Cargo Advanced Screening program will likely become mandatory this summer when published in the Federal Register. This means that prior to a shipment moving by air into the United States, whether by passenger or all-cargo aircraft, CBP wants house air waybill level data that will go through their targeting systems to look for potential dangers to the air cargo supply chain. A number of activities have prompted the agency to move forward with ACAS, including an incident in Yemen with printer cartridges a number of years ago and most recently in Australia.
RIM is working with both our own offices overseas as well as in countries where we use partners to ensure that when the announcement is made, we are ready to continue to seamlessly move air cargo into the United States.
– Sandy Gregory