Leah Ellis, Compliance Specialist at JAS Forwarding USA Inc, was the guest speaker at the Atlanta International Forwarders & Brokers Association Monthly meeting where she presented a training session on Customs ACE Portal. She reviewed how to navigate through the portal and reporting tools available for Importers, Exporters and Brokers. She has also conducted a seminar with the Houston Broker’s Association on the ACE Portal.

Additionally, Laurie Arnold, Regulatory Compliance Offer at JAS Forwarding USA Inc, was invited to be a guest speaker at the Importer Seminar for the Midwest Global Trade Association. She spoke on the hot topic that all customs brokers would desperately love to provide input to “What Can Importer’s Do to help their Customs Broker?” Her presentation and input was well received!

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For more information on JAS Compliance and speaking engagements, please contact compliance@jas.com.

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Developing an Export Compliance Program

Date: April 27, 2017

Location: Portsmouth, NH

Developing and maintaining an export compliance program is highly recommended to ensure that export transactions comply with the Export Administration Regulations (EAR), and to prevent export control violations. This one-day workshop provides an overview of the steps a company may take to implement an internal Export Compliance Program.

https://www.bis.doc.gov/index.php/compliance-a-training/export-administration-regulations-training/seminar-details/1220-april-27-2017-portsmouth-nh

Georgia Logistics Summit

Date: May 16 – 17, 2017

Location: Atlanta, GA

The Georgia Logistics Summit is an event that brings more than 1500 logistics professionals to learn best practices and connect with industry decision makers. Registration is now open!

http://www.cvent.com/events/2017-georgia-logistics-summit/event-summary-173feb5695f6427bb175e17df60c38ac.aspx

Complying with U.S. Export Controls

Date: June 8-9, 2017

Location: Seattle, Washington

This two-day program is led by BIS's professional counselling staff and provides an in-depth examination of the Export Administration Regulations (EAR). The program will cover the information exporters need to know to comply with U.S. export control requirements on commercial goods.

https://www.bis.doc.gov/index.php/compliance-a-training/export-administration-regulations-training/seminar-details/1206-june-8-9-2017-seattle-wa

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WHY IS IT OF UTMOST IMPORTANCE IF IMPORTING FDA MERCHANDISE?

May 27, 2017 will be the start date for the US FDA to begin implementation of the Foreign Supplier Verification Program or FSVP. Per FDA website “The final rule requires that importers perform certain risk-based activities to verify that food imported into the United States has been produced in a manner that meets applicable U.S. safety standards.” Further, FSVP “…is a program that importers covered by the rule must have in place to verify that their foreign suppliers are producing food in a manner that provides the same level of public health protection as the preventive controls of produce safety regulations, as appropriate, and to ensure that the suppliers food is not adulterated and is not misbranded with respect to allergen labeling."

The FDA website cited below bullet points actions which importers are responsible to undertake:

• Determine known or reasonably foreseeable hazards with each food
• Evaluating the risk posed by a food, based on the hazard analysis, and the foreign supplier’s performance
• Using that evaluation of the risk posed by an imported food and the supplier’s performance to approve suppliers and determine appropriate supplier verification activities
• Conducting supplier verification activities
• Conducting corrective actions

FDA notes that “Importers must establish and follow written procedures to ensure that they import foods only from foreign suppliers approved based on an evaluation of the risk posed by the imported food…” An FSVP is needed for all food coming to the United States. If an importer sources one particular food from numerous suppliers, each supplier will need an FSVP.

So who is the FSVP importer? Quoting the FDA website citation below “For the purposes of FSVP, an importer is the U.S. owner or consignee of a food offered for import into the United States.” It is important to note that if there is no U.S. owner at the time of entry into the U.S., then the foreign owner of the food must appoint a U.S. agent. Per the Federal Register published November 27, 2015, “If the article of food has not been sold or consigned to a person in the United States at the time of U.S. entry, the importer is the U.S. agent or representative of the foreign owner or consignee at the time of entry. JAS Forwarding USA Inc. cannot fulfill this function."

What to do? Now is the time to get familiar with these regulations. First, confirm if you are importing food. If so, then focus a great deal of attention on developing a process for FSVP for each supplier. It is important that each importer check the rules and confirm if they are by definition the FSVP importer. Also note that starting on May 27, 2017, each importer’s broker will need for each line of food product importing into the U.S., the name, contact information, DUNS#, and FDA registration number of the FSVP Importer. This information will be reported in ACE at time of entry starting on May 27.

While it is reasonable to expect a soft launch with regards to compliance and targeting by FDA, it is important to proactively work toward compliance quickly. If you need help determining what this means for you, contact JAS Forwarding USA Inc. Compliance today and we can help!

https://www.fda.gov/food/guidanceregulation/fsma/ucm361902.htm

https://www.federalregister.gov/documents/2015/11/27/2015-28158/foreign-supplier-verification-programs-for-importers-of-food-for-humans-and-animals

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"Descartes Systems Group, the global leader in uniting logistics-intensive businesses in commerce, announced that JAS Forwarding Inc. is using the cloud-based Descartes Air Cargo Advance Screening solution to provide enhanced security for air cargo coming into the United States," stated an article by the American Journal of Transportation. The Air Cargo Advanced Screening initiative was created by CBP in order to gather data about the parties and commodities involved in air cargo, before loading takes place on an aircraft at a foreign port. This initiative is in the pilot phase currently. CBP has also been able to communicate with the air industry to determine the best ways of achieving the desired regulatory results without affecting the speed of air cargo operations.

From the article:

“Technology innovation remains a cornerstone of our mission to ensure worldwide transparency and an efficient supply chain for our customers by delivering their cargo on time and securely,” said Laurie Arnold, Regulatory Compliance Officer at JAS Forwarding Inc. “With the Descartes solution, we’re not only an early adopter of the ACAS pilot program but are sharing information with CBP further back in the supply chain to help identify high-risk air shipments into the U.S. while accelerating the movement of low-risk shipments.”

Read More

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