Every five years, the World Customs Organization (WCO) revises the Harmonized System, the last one, as you all know took effect on January 1, 2007. Well, be prepared for the next update which CBP probably will announce after they get the correlation tables ready perhaps later this year.
Below you will find the link to the WCO-published HS amendments to enable an early start for all you importers and compliance folks out there.
You will surely notice the extensive revision in Chapter 3 and the detailed identification of various species of fish. One could assume this is necessary for accurate capture of trade data to help in formulating future environment policies because of continued and excessive fishing. In addition, illegal logging and the Lacey Act could have been better assisted with more scrutinized modifications in Chapter 44 and 48, wood and paper, respectively, rather than some skimpy description revisions.
Amusingly a new subheading note to Chapter 24 reveals for the first time ever, "water-pipe tobacco" and world customs' classy description of its embellished form that is smoked in great volumes in hookah bars of Adams Morgan-DC, Sunset Boulevard-West Hollywood and in almost every hip gathering hole in most U.S. cities every evening. Smiles are brought to the fore while reading, "containing aromatic oils and extracts, molasses or sugar, and whether or not flavored with fruit" hiding a vision of mysterious locales in the far corners of Morocco, India, Egypt, Syria and other exotic places. But surely, hookah bars mushroomed way before 2007, WCO's last HS revision. No one smoked hookah in Brussels at that time, we presume!
Watch for other changes in Chapters 29 and 30 for chemicals and pharmaceuticals in which new sub headings have been created for substances controlled under international conventions such as the Rotterdam Convention that monitors the international trade in hazardous chemicals and the Montreal Protocol, an international agreement designed to protect the earth's ozone layer by stipulating the phase-out of the production and consumption of depleting compounds.
Major revisions are not evident in Chapters 84 and 85 that was seen in 2007. However, it is pleasing to note the creations of new sub-headings 8507.50 for Nickel-metal hydride
and 8507.60 for Lithium-ion batteries. With the profusion of hand-held electronic devices, these categories are welcome additions.
But what of other products that are of so much concern to the world these days. Should not environment-enhancing goods be separately identified to promote duty-free trade in them? How about addressing nuclear proliferation by extricating each description of all the major components of such a weapon and putting it in its respective HS chapter? Going into details of munitions, for example, take cannon ammunition that is 20 mm to 57 mm which is presently lumped under 9306.30 that also contains cartridges for rifles and pistols. Is not the international trade in small weapons and their ammunition of concern to border security agencies the world over, especially in the trouble spots we read about daily? New, unique HS sub-headings for such products would provide for accurate data acquisition and steer global policy for a much safer and cleaner world.
The Harmonized System Nomenclature to enter into force on 1 January 2012 is published on WCO's Public Web Site: http://www.wcoomd.org/files/1.%20Public%20files/PDFandDocuments/HarmonizedSystem/HS%20Overview/HS2012E.pdf
The WCO web site is http://www.wcoomd.org/
Monday, July 19, 2010
Thursday, June 24, 2010
Do AES Corrections make sense?
Submitted by an ICPA member
In a recent response to an inquiry regarding AES horror stories, there was mention of routing changes by couriers due to the volcanic disturbances over the North Atlantic which caused the port of export to change. It was mentioned that if this detail was not corrected, the > filer would be subject to a hefty penalty. We understand that AES filings serve two major purposes - [1] providing > statistical data on value, reporting units per HTS [Sch B] to which foreign destinations and [2] advising where the shipment is located so an inspection could be made, if desired. We file our own AES - [99.75% accuracy over 5 years vs. 1.3% accuracy when we did not file our own] Our freight forwarder automatically emails "confirmed on board" notices for air and ocean shipments. The couriers do not. Any last minute change in the port of export does not affect the "balance of payments" data that is being collected. Is it really necessary to submit a change in the port of export - after the goods have been exported? What purpose does it serve? With over a thousand courier exports per month, this would be a monumental task to track each shipment to verify the flow from shipping point to final departure from the US. Our inquiries to Census have resulted in "accurate data is required". Does that mean a change in weight from 12,500 kgs to 12,499 kgs should be corrected? A reported departure of Friday, was actually exported on Saturday. Does that need to be corrected? Some of these variances do not seem to be significant. Having to hire additional staff just to revise these minor changes would not be acceptable. The result would be a decrease in the number of exports as we find them to be too costly to monitor. I thought our government wanted to promote exports. We have cleaned up the accuracy of data submission over the last several years, but do not think it is fair to the exporting community to become mired down in insignificant adjustments. Our audits of Routed Transactions indicate that most of them reflect shipping data far different from what we provided. This is not easily auditable by the government [that is why the values, classifications, etc are changed]. We cannot believe that so much "garbage" is accepted and then penalties will be issued for a change in departure airports!
In a recent response to an inquiry regarding AES horror stories, there was mention of routing changes by couriers due to the volcanic disturbances over the North Atlantic which caused the port of export to change. It was mentioned that if this detail was not corrected, the > filer would be subject to a hefty penalty. We understand that AES filings serve two major purposes - [1] providing > statistical data on value, reporting units per HTS [Sch B] to which foreign destinations and [2] advising where the shipment is located so an inspection could be made, if desired. We file our own AES - [99.75% accuracy over 5 years vs. 1.3% accuracy when we did not file our own] Our freight forwarder automatically emails "confirmed on board" notices for air and ocean shipments. The couriers do not. Any last minute change in the port of export does not affect the "balance of payments" data that is being collected. Is it really necessary to submit a change in the port of export - after the goods have been exported? What purpose does it serve? With over a thousand courier exports per month, this would be a monumental task to track each shipment to verify the flow from shipping point to final departure from the US. Our inquiries to Census have resulted in "accurate data is required". Does that mean a change in weight from 12,500 kgs to 12,499 kgs should be corrected? A reported departure of Friday, was actually exported on Saturday. Does that need to be corrected? Some of these variances do not seem to be significant. Having to hire additional staff just to revise these minor changes would not be acceptable. The result would be a decrease in the number of exports as we find them to be too costly to monitor. I thought our government wanted to promote exports. We have cleaned up the accuracy of data submission over the last several years, but do not think it is fair to the exporting community to become mired down in insignificant adjustments. Our audits of Routed Transactions indicate that most of them reflect shipping data far different from what we provided. This is not easily auditable by the government [that is why the values, classifications, etc are changed]. We cannot believe that so much "garbage" is accepted and then penalties will be issued for a change in departure airports!
Tuesday, June 22, 2010
Phoenix 2011!
It is not too soon to start thinking about the 2011 ICPA conference in Phoenix.
One of the features of the conference will be the workshops on the last day. The ICPA conference already has a reputation for being a "hands-on" type event. The workshops will be the epitome (is that a good word?) of this. John Priecko and I were asked to do the planning for the workshops. There will be both export and import sessions. We are already finalizing the subjects and beginning to identify potential speakers. Stay tuned to the ICPA site for news on the conference and plan to be in sunny Phoenix next March. Be sure to include the workshops in your plans!
One of the features of the conference will be the workshops on the last day. The ICPA conference already has a reputation for being a "hands-on" type event. The workshops will be the epitome (is that a good word?) of this. John Priecko and I were asked to do the planning for the workshops. There will be both export and import sessions. We are already finalizing the subjects and beginning to identify potential speakers. Stay tuned to the ICPA site for news on the conference and plan to be in sunny Phoenix next March. Be sure to include the workshops in your plans!
Thursday, June 3, 2010
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