Importing and exporting can be an important part of your business and finding a strategic partner to assist with your international trade development and on-going processes can make a world of difference. You need a consultant that understands the details and appreciates the myriad ways of implementing the right practices for your organization. WD offers unmatched professional support in all areas of International Trade Compliance.
Export Administration Regulations (EAR)
The U.S. export laws are designed to control sensitive goods and technologies. The liability of your company is on the line and compliance with all relevant export laws is extremely important. There are regular steps that should be taken to ensure compliance in this crucial area and WatsonDavis offers considerable experience in conducting export assessments.
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Review written company policy and Export Compliance Management Programs
Review product classifications for periodic updates in the ECCN system
Review licenses for continuations, renewals, and adherence to conditions
Review Electronic Export Information (or AES report submissions) for errors and corrections
Verify Citizenship status of Foreign Nationals at the Company and the projects each are exposed to or participating in specialized projects.
Verify personnel handling export transactions have been trained in the required areas of knowledge for export such as; "red flags", End Use/ End User and Denied Parties.
Periodic audits – both internal (suggested quarterly) and external (suggested annually or biannually)
Reports to senior management on status of export programs and suggested improvements
Prepare and supply/conduct export related training specific to your organization and products
Conducting a thorough review of any of the areas noted above while evaluating your current procedures for possible improvements can put you ahead of the "risk" game and keep you competitively and economically prepared.
Every commodity has both a HTS classification under the US Harmonized Tariff System and an Export Control Classification Number (ECCN) under the Commerce Control List. Determining these identifiers for your product is critical to knowing if you need to obtain a license prior to export, or knowing the duties, taxes and restrictions associated to your product at import. Specific expertise applied to this area of your business can minimize your risk and save you time and money.
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In order to accurately classify product a detailed analysis and comprehensive knowledge of the HTS, Customs rulings and practices are required. The ECCN classification for export requires an even more detailed level of assessment. Companies often choose to outsource this essential function to secure the most effective evaluation and support reasonable care principles.
Our approach takes the following into consideration:
Detailed description of product and what it is
Detailed review of information concerning product identification and make-up
Detailed review of materials used to manufacture or assemble the product
Product function (what does it do – what can it do?)
Previous Customs rulings of similar product already classified
Similar product evaluations or Commodity Classification Rulings from BIS
Reviews of previously classified material need to be conducted on a periodic basis as the regulations change. Consider a export/import consultant on retainer to your organization as a skilled advantage to your bottom line. We even have the ability to submit Commodity Classification Requests, (CCAT reviews) via the SNAP-R system on your behalf.
Currently there are substantial export reform rules that will be taking effect in October of 2013. This new law will have far reaching effects on the US export regulations for both ITAR and EAR. It is especially important that your product be reviewed prior to the implementation of these new laws.
To review the Federal Register Notice of the new
rules go to:
License Research & Application Filing
An export license grants permission to conduct a certain type of export transaction. It is issued by the appropriate government agency after a review of the facts provided in an application for export. Only a small number of exports required a license based on determinations of the individual transaction and the characteristics and technology of the product or technology. WatsonDavis is skilled at researching products, technology and deemed export specifications to determine if a license or license exception should be applied.
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If the product or technology is a defense article or service found on the US Munitions List (USML) an export license from the US Department of State issued by DDTC (Department of Defense Trade Controls) will be required.
If the product is not on the USML the product must be classified for ECCN under the Commerce Control List. The export license determination will be based on the specified reason for control and the country of destination and end use.
WatsonDavis can assist with preparing applications for both agencies. In additional WD is an approved active account user with a registered CIN in the SNAP-R electronic system allowing us to submit BIS applications via the web on your behalf, making the process more efficient and saving valuable time in getting the product to your global customer.
AES Electronic Filings
- Automated Export Information. Yes, SED/EEI is being re-engineered (again) and will provide an extensive and traceable interface for the reporting of all export data across all modes of transportation. This is the electronic export data that is mandated and must be filed in the Automated Export System (AES). If you are a self filer or a freight forwarder filing on behalf of a shipper we can help prepare and train your people for the new system and how to file this important export document correctly on line.
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We can assist with all aspects of AES including:
Quarterly and Annual AES Audits
Getting you registered as a user for AES Direct
Obtaining references and help with various screens and tables used when filing a shipment
Response Message Resolution
Proof of Filing Citations
Shipment Manager – report reviews and resolutions of errors