Bearing Importers Celebrate!

Effective July 16, 2011, ball bearings and parts from Japan and the United Kingdom will no longer be subject to antidumping duties.  The Department of Commerce issued the initial order on May 15, 1989.  This means Customs and Border Protection has been collecting dumping duties on ball bearings from Japan and the U.K for over 20 years.  The initial sunset reviews reported that the potential for continued material injury to the industry existed.  After reviews by the International Trade Commission in August 2010 and March 2011 On April 20, 2011, the ITC determined that revocation of the orders would not likely lead to material injury. The Court of International Trade affirmed this decision in April 2011 in the case of NSK v. United States. While the issue bounced back and forth between the CIT and the CAFC the decision was stayed; however, the stays were lifted on July 6, 2011.  In keeping with the CAFC’s decision, the Department of Commerce revoked the antidumping orders on ball bearings and parts from Japan and the United Kingdom.   A list of potential Harmonized Tariff numbers affected by the ruling can be found in the Federal Register published on July 25, 2011.

Good Impressions

Making a good impression is important. Not only do job applicants face stiff competition, but businesses must also compete for customers. You may have seen some of the articles about how posting certain pictures and personal information online in the social networking sites may affect your ability to get a job. This article continues that topic by looking into how what you write may affect you and your employer.


Consider this email sent by the owner of a small company to a consultant who is interested in forming an alliance with the company.

hi joe. i enjoyed meeting you yesterday and am interested learning more about your business.

Some questions:
1) est. number of customers?
2) do business with our competitors?
3) customer status within organization?

as we discussed, i see opportunity here for a mutually beneficial alliance.

our company offers _________ as well as ________. additionally, we've partnered with___________ to supply everything from _________ to _________________.

we can customize our products to suit your customers, altho it might not be necessary.
let me know. thanks


If you received this email, what would you think? Would you respond?

Now, consider the communications you send to customers and others.  Are you making a good impression, representing your company in a positive manner and instilling confidence in  your company's capabilities?

We invite you to share your thoughts and experiences with our readers

The Importance of Continuing Education in Trade Compliance

Companies involved in international trade understand that laws, regulations and government expectations change regularly.   By the time the organization gets used to one regulation, the government changes the rules.  These frequent changes and the nature of the business make it necessary for international compliance employees and other stakeholders to keep track of current events.    An indispensable component for any effective trade compliance program is continuing education.  When conducting a Focused Assessment, C-TPAT validation or other review of the importer’s import compliance function, Customs and Border Protection “CBP” auditors request information about the training employees receive.  Continuing education has many benefits; however,   failure to provide adequate training could cost the organization in fines, penalties and reputation.

Training employees who are directly and indirectly involved in the trade compliance is one of the key ingredients in a company’s continuing education program. CBP makes it clear that it is important for all employees to be aware of their responsibilities related to trade compliance.  Trade compliance is a cross-functional endeavor; therefore, employees in accounting, purchasing, shipping/receiving, logistics, manufacturing, engineering and others with trade-related responsibilities receive annual training. Another best practice involves providing new employee with some type of trade compliance training that covers the roles of import and export compliance.  Companies participating in C-TPAT must ongoing training for employees, visitors and business partners so that they are aware of the security requirements.

For many companies, continuing education is low on the priority list when it comes to allocating funds in the budget; however, CBP indicates that these activities are part of doing business. You may be thinking that there is a “hook” coming and this article is going to try to sell you something.  Read on.  You will not find a sales pitch to purchase any training programs or enlist the services of a trade professional.

Some of the CBP publications that emphasize the importance of continuing education include the Focused Assessment (Exhibits 2A, 3B, 3D, 3E and 4A), 19 CFR 111.1 and the C-TPAT Minimum Security Criteria for Importers.

During a Focused Assessment (FA) auditors may review of the records of continuing education importers and brokers provide. The FA presents clear examples of the importance CBP places on employee training.  Several sections of the FA provide questions that specifically require the importer to provide information related to training and the lack of training creates red flags for the auditors.  If there is any doubt that CBP values training, the sample importer procedures provided in Exhibit 4A should remove those doubts.   The CBP Regulations (19 CFR) specifically mention training as an element of responsible supervision for customs brokers. 

Now that we understand the importance of continuing education let’s look at some of the benefits of education. Some of the general benefits of training include:

·         Increased productivity and improved quality of work.

·         Improved employee morale and reduced turnover.

·         Increased  accuracy, quality and compliance

·         Increased profits and customer satisfaction.

 

If you still need more information to support your pitch to management, consider comparing the cost of training with the potential penalties and negative publicity your company could face. Before approaching management for support and funds, be sure to do your research into the training you need.  You will want to compare the various options available.  What training topics will need to be outsourced?  What type of platform is best suited for your organization.  Continuing education comes in a variety of packages, each with benefits and costs.   You may be able to develop some training in house for little or no cost to the organization.  Other options include bringing in expert speakers, sending employees to seminars, purchasing online courses, providing on the job training and more.

Regardless of your approach, continuing education is an essential, not optional, part of a successful trade compliance program. Government agencies make it clear in various publications that continuing education is expected.   Continuing education provides a number of benefits that actually work to reduce unnecessary expenses and penalties while increasing compliance, productivity, employee morale and customer satisfaction.  There are numerous training tools available for trade compliance professionals from seminars to online courses.  Consider the needs of your organization, budget and types of programs available. Then, develop a continuing education program that satisfies your organization’s compliance needs.