Transcript None - Long Island Import Export Association

Long Island Import Export Association
Impact of Trade Compliance on Importers & Exporters
*connectedthinking
PwC
Topics to Be Discussed
CTPAT
10 + 2 Proposal
AEO (Authorized Economic Operator – EU Program)
FTA Compliance (Free Trade Agreement)
C-TPAT
 C-TPAT is a voluntary government-business initiative to build cooperative
relationships that strengthen the overall international supply chain and U.S. border
security.
 C-TPAT is centered around the concept that the highest level of security can only
be achieved through close cooperation with the ultimate owners of the supply
chain— importers, carriers, brokers, warehouse operators and manufacturers.
© 2008 PricewaterhouseCoopers
Slide 3
Where is Customs Going With C-TPAT?
 Already in progress:
 Detailed verifications of applications
 Tighter container seal control
 Tighter documentation control
 New security criteria - importers now seeking to join the C-TPAT program will
need to meet or exceed the new security criteria before they will be certified.
 Wish list:
 Smart containers and possibly even tracking systems
 Extensive screening (initial & ongoing) of personnel. This includes both
foreign and domestic locations.
 Security/C-TPAT requirements by importers for their entire supplier base and
logistics providers.
© 2008 PricewaterhouseCoopers
Slide 4
C-TPAT & Supply Chain
 Financial & compliance costs to ensure the integrity of security practices and
communication of security guidelines to business partners within the supply chain
 The supply chain, for C-TPAT purposes, is defined from point of origin
manufacturer/supplier/vendor through to point of distribution.
 Customs has acknowledged that its likely that at least portions of C-TPAT may
become mandatory in the near future (e.g., regulations pertaining to seals)
© 2008 PricewaterhouseCoopers
Slide 5
Customs “10 + 2” Proposal
 Importers required to submit an Importer Security Filing containing certain data
elements (the “10” of the “10 + 2”)
 Carriers would be responsible for a vessel stow plan and container status messages
(the “2” of the “10 + 2”)
1. Manufacturer/Supplier name and
address
2. Seller name and address
3. Buyer name and address
4. Ship to name and address
6. Consolidator (stuffer) name and address
7. IOR/FTZ applicant identification number
8. Consignee number
9. Country of Origin
10. HTSUS number (6-digits)
5. Container stuffing location
© 2008 PricewaterhouseCoopers
Slide 6
Customs “10 + 2” Proposal
 Financial & compliance costs to develop procedures to comply with additional
filing requirements
 Communication of procedures and requirements to business partners within the
supply chain
 Potential Supply Chain Delays
© 2008 PricewaterhouseCoopers
Slide 7
AEO

The EU Commission, following the US and SAFE (the WCO framework of
standards), initiated its safety and security program ‘the authorised economic
operator’ by publishing security amendments in the Community Customs Code,
making these amendments directly applicable for all Member States.

The AEO concept is an initiative of the EU Commission:
 In realizing faster and better-targeted customs controls under a common riskmanagement framework
 In controlling supply chains that only contain reliable trade partners
 In adapting the WCO Framework of standards to ensure trade facilitation
(instead of trade disruption)
 Along with pre-departure and pre-arrival information
 Governed through and by electronic data-exchange
© 2008 PricewaterhouseCoopers
Slide 8
AEO



The ‘authorised economic operator’ concept is a status (voluntary program), based
on granting a company one of three possible certificates:
 The certificate ‘customs’ (simplified procedures)
 The certificate ‘safety’ (securing the supply chain)
 The certificate ‘customs and safety’ (a combination)
Most Member States have started with the development of an AEO certification
scheme based on self-assessment.
Main concerns expressed are:
 Mutual recognition (EU level and internationally)
 Enforceable nature of the certificate, and the different approach between
Member States (AEO shopping)
 Use of other certification schemes
© 2008 PricewaterhouseCoopers
Slide 9
Managing Global FTA Compliance

Impact both buyer and seller
 Cost of sales/purchase price
 Import & export licenses

Impact of compliance
 Usage of numerous agreements and maintenance of compliance programs
 Burden of collecting supporting data and certificates

Supply chain considerations (e.g. landed cost analyses)
© 2008 PricewaterhouseCoopers
Slide 10
Thank you.
Worldtrade Management Services
300 Madison Avenue
New York, NY 10017
(646) 471-2371
[email protected]
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