United Global Sourcing Importing & Exporting Blog

Have you ever needed to see a physical prototype of your 2D or 3D drawing and need it in a hurry? At UGS, we have the solution. As part of the services that we offer our customers we now have a Dimension SST1200 3D printer that will take your STL format (i.e. Solidworks, IGES or other 3D format) and convert it to an actual physical part using ABS plastic material.

This process in most cases takes less than one day to perform and will give you your part to within thousandths of an inch of your parts size. Highlights include:

· Receiving your 3D prototypes within 2 – 3 days of submitting computer blueprints.

· Saving money and time in product development.

· Test form, fit and function with 3D printed model.

· All working models produced in durable ABS plastic.

· Standard colors available are white, red, blue, green, gray, yellow and red (other PMS colors available upon request).

· Single piece construction up to 56.3 cu. inches.

· 3D prototype parts can be used in sales presentations as visual aids.

· 3D samples are excellent masters for vacuum forming.

We have used this process for many of our customers as added value and service to help our customers sell to their customers! Another reason to consider UGS as your full service overseas manufacturing source. Contact us to discuss complete pricing for your project.

Finally, CBP has agreed to issue an interim rule for the Import Security Filing commonly referred to as 10+2, as opposed to a final implementation.  The fact this was issued as an interim rule highlights the fact CBP has taken into consideration many of the trade’s concerns.  The following are the key areas that have been amended from the initial Notice of Proposed Rule Making (NPRM).

1)  CBP will “show restraint in enforcing the the rule for a period of 12 months after the effective date.  The effective date will be 60 days from the date of publication – January 26, 2009.

2)  Two of the twelve elements will subject to flexibility as to the timing of their submission to CBP.  This includes the Container stuffing location and the Consolidator (stuffer) name and address.   The importer must submit these elements as soon as possible and no later than 24 hours prior to arrival in a US port.

3)  Four elements will be subject to flexibility with respect to interpretation.  These elements include the Manufacturer (supplier), Ship-to party, Country of Origin, and HTS number.  CBP will allow a range of acceptable responses based on facts available to the importer at the time, but the elements must still be filed 24 hours prior to loading.  The importer will then be required to update their filing of these elements as soon as accurate information is available and no later than 24 hours prior to arrival at a U.S. port.

4)  The liquidated damage amount for violations has been changed from the value of the cargo to $5,000 per violation.

5)  The requirement for break bulk cargo to be included on vessel stow plans has been eliminated.

6)  Container Status Messages (CSM) are required for empty containers.

7)  The label for the party required to submit the ISF has been changed from “importer” to “ISF importer” meaning the owner, purchaser, consignee, or agent.

8)  Provisions were made to create an Importer Security Filing Bond (19CFR 113.63).

9)  Powers of Attorney must be in English and POA’s as well as letters of revocation must be kept for five years from revocation date.

Basically, CBP has made some changes in response to comments from the trade but many requirements remain unchanged.  The phased-in approach provides importers a chance to work through the challenges without immediate penalties as well as the opportunity to provide additional feedback to CBP.  The next 14 months will be challenging as importers try to ramp up to meet the requirements of another security initiative as they also strive to cut costs and increase efficiency while remaining competitive.

Should you have any questions/concerns related to your freight movement under this new initiative, please feel free to contact us directly.  UGS is working daily with our service providers to ensure we are ready to meet the challenges presented by the implementation of 10+2.

The Consumer Product Safety Act (CPSA) final ruling eliminates the requirement for foreign manufacturers who export to certify their goods conform with applicable CPSA product safety standards.  The importer of foreign manufactured will be solely responsible to issue conformity certificates for imported goods.

The rule also clarifies that certificates can be electronic and satisfy the requirements of a) accompanying the shipment, and b) furnished to distributors/retailers.  This can be accomplished by using a unique shipment identifier that can be accessed via the Internet to eliminate concerns regarding confidentiality of imported products.

It is still critical for importers to determine the standards that apply to their products and ensure those standards are being met, a task that is complicated by the fact new rules and guidelines seem to be issued weekly.  All importers should take note after an initial adjustment period, the failure by an importer to abide by the certificate of conformity requirement will result in shipments being denied entry and/or destruction.

All importers should remember it is the Customs Inspector at the port initially making the determination whether or not to hold a shipment and as we all know this “interpretation” of new regulations varies dramatically from port to port.  I would not be surprised to see a larger than expected volume of shipments being held while CBP Headquarters sends some directives to the officers at the ports on how to handle and process shipments under these new guidelines.

The controversial Clean Truck Fee (CTF) assessed by the Port of Los Angeles and Port of Long Beach that was scheduled to begin on November 17, 2008 has been indefinitely delayed in order to finalize certain procedural issues. The CTF imposes a fee of $70 for an FEU and $35 for a TEU.  The arrangement between the two shipping ports and PortCheck (the company contracted to collect the fees) is pending approval by the Federal Maritime Commission.

The Federal Maritime Commission said October 29th that it would ask a U.S. District Court to strike down portions of a landmark pollution-control program at the ports of Los Angeles and Long Beach, the nation’s busiest international cargo complex.

Elements of the ports’ clean truck program are likely, by a reduction in competition, to produce an unreasonable increase in importing and exporting of goods, transportation cost or unreasonable reduction in service.

The new anticipated launch date has yet to be published.  United Global Services (UGS)  continues to monitor this situation to avoid delays in freight movement for our customers who are involved in over seas manufacturing, importing of manufactured goods and exporting of goods from the USA.

The new Customs and Border Protection e-Allegations website provides a venue for the public to report any suspected violations of trade laws or regulations related to the importing of goods into the United States.  These violations include but are not limited to false country of origin markings, health and safety issues, intellectual property rights, and trademark and copyright infringement.

The system allows anonymity for concerned citizens who have knowledge of trade violations that are damaging to the U.S. economy and the general public.

UGS customers with trademarked or copyrighted items should contact us immediately if they have knowledge of an illegal import of their product.  We will guide our customers through the e-Allegations website and follow-up to ensure our customer’s products are protected against knock-offs by competitors who then attempt to import these same products in the U.S.

Safe Port Act of 2006

Customs and Border Protection acting on provisions of the Safe Port Act of 2006 will require additional data elements from importers to improve targeting of high-risk freight.  This filing will include ten (10) data elements from the shipper/importer and two (2) elements from the carrier.  The filing is to be done one time inclusive of all twelve (12) elements.

10+2 is an ocean container security filing submitted by the importer and carrier to CBP 24 hours prior to vessel loading in the foreign port.  This currently applies only to containerized cargo – exemptions include break bulk and RoRo (roll on roll off) freight.

The final ruling has not yet been published on 10+2 but is expected within the next weeks.  UGS is working with our partners and service providers to ensure compliance and seamless transition for our customers under this new security initiative.

The House Ways and Means Committee has asked the International Trade Commission to review imports of textiles and apparel from China and report the findings to Congress.  The domestic textile industries are concerned once the trade restrictions are lifted on December 31, 2008 there will be a surge in imports from China that will jeopardize U.S. jobs.

This paves the way for possible Anti-Dumping/Countervailing Duty cases and other restrictions to be imposed on these imports from China to protect the U.S. textile industry as well as that of developing countries who import U.S. manufactured textiles under preferential trade agreements.

The Consumer Product Safety Improvement Act institutes new import requirements for consumer goods effective November 12, 2008.  This is a direct result of tainted products imported from China, e.g., lead paint in toys, melamine found in various food items, etc.  This Act covers almost all consumer goods including fabric, wearing apparel, toys, jewelry, sporting goods, refrigerators, furniture, hazardous materials and even some pharmaceuticals with child resistant caps.

The new certificates must be self-issued, based on a reasonable testing program, must be issued by two to three participants in the supply chain, must accompany the product, and must be furnished to each distributor and/or retailer of the product.  If no certificate is issued or a false certificate is ascertained, the shipment may be refused admission and destroyed.

UGS currently follows customer directives related to product testing utilizing accredited laboratories and is closely following the directives related to this Act to ensure all laboratories utilized will meet the new accreditation requirements.

LCL: Less than Container Load: When your shipment does not fill a 20’/40’ container it is combined with other shipments in a container then sorted at the port of destination for delivery.

TOOLING: A jig or template of your item(s) is made in order to mass produce more easily.

ETD vs. ETA: Estimated Time of Departure: When your shipment leaves the factory. Estimated Time of Arrival: When your shipment is due to be delivered to your door.

MOQ: Minimum Order Quantity: When quoting, this may exceed your originally requested amount. This is the least number of pieces the factory can make taking into consideration all costs. (material, labor, etc.)

C-TPAT: Customs – Trade Partnership Against Terrorism: A program where importers volunteer to utilize more strict security practices, while in association with Customs.

UGS is proud but simultaneously feeling a great loss, as long-time employee Natalie Mead has resigned from the company. Natalie intends to continue her education full time in the nuclear medicine field. Anyone who has worked with her knows a spirit like hers cannot be replaced easily. We’ll miss her!