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info@3rdwave.co3rdwave.co+1 (416) 510-8800 1
Managing Customs & PGAs
A Total Perspective for Importers
Edward (Ned) Blinick
Chief Product Officer
A Q&A with Gregg Cummings,
Managing Partner, Strix LLC
eblinick@3rdwave.co
2
About Gregg
Gregg has more than 25 years of experience in the International trade industry and
Corporate Finance. He is a Managing Partner of STRIX, LLC a leading company in Self-
Filing Software, International Freight, Domestic Trucking and Logistics. He is also the
President of TBI Brokers, Inc., the firm's Customhouse Brokerage.
Gregg is recognized as an expert in the area of customs automation for ISF and Entry filing
and provides important consulting services to companies who seek to bring processes in
house as well as marrying full service brokerage automation and hybrid solutions. He is an
active member of the International Compliance Professionals Association (ICPA) and speaks
frequently on the topics of how importers can streamline their import processes via
automation and internal control.
AGENDA
WONDERFUL WORLD OF ACE
Changes, challenges, Opportunities
PGAs complex challenges
Gaining Competitive Advantages
TRADITIONAL ROLES OF CBP, IMPORTER, BROKER
Historically and Today
Flexibility and Control of Data
IMPORTER CASE STUDIES
Brokers point of view
Importers point of view
THE ROAD AHEAD
Best practices
Current regulatory environment
4
Unique position in marketplace
Full Service Customs Broker
Cloud based Self-Filing Solution
Formerly
5
The ACE environment forever changes the
relationship between CBP and the Importer
This is a positive and needed direction
Single Window makes sense for todays technology
PrePost
6
Changes mean Challenges
Challenges mean Opportunities
Opportunities mean Competitive Advantages
7
What are the Main Changes
Entry Summary
Cargo Release
PGAs
CEEs
8
The Main Challenges
ACE Entry Summary
ACE Cargo Release
ACE System Downtime
ACE System Message sets
9
PGAs remain the Complex Challenge of ACE
FDA
APHIS
DOT
EPA
10
Opportunities begin by exploring the Traditional
Roles between CBP, the Importer and the Broker
Complex challenges always provide Opportunities
11
CBP Roles and Responsibilities
Complex challenges always provide
Opportunities
Then:
US Customs
Reported to Treasury
Collect Duties and Fees
Enforcement
Collect Trade Data, Census
information
Now:
Homeland Security
Security,
Enforcement
Pendulum Swing back to
more traditional
enforcement
Complex challenges always provide Opportunities
Customs Brokers Roles and Responsibilities
Then
 Primary interface between Importer and Customs
 Oversight of Import Clearance
 Collate Documentation
 Classify goods
 Communicate to Ports
 Full Service
Now
 Not Necessarily primary interface with Customs
 Tougher legal and Regulatory Environment
 Greater push/pull for Importer to Classify
 Greater push/pull for Importer to Collate Docs
Traditional Roles of Importer
Complex challenges always provide Opportunities
Then
 Relied on Broker to provide Service Interface
with Customs
 Process a Mystery
 Visibility Limited
 Penalties for non-Compliance High
Now
 Todays Technological and Legal
Environment
 Process a Mystery no longer
 ACE Portal
 Importer provides most documentation
 Importer classifies goods
 Must audit ISF and Entry files
 Visibility on par with Broker
14
Are you in Control or Out of Control?
Todays Importer has greater Flexibility and
Options than ever before
Lower Pricing for Brokerage
Options to Self-File
Options to Hybrid File
Automation
Automate Self-Filing
Automate Brokerage
15
Its The Data Stupid!
16
Controlling the Process begins by Controlling
the Data
Importer Case Studies
How does a Broker do this?
How can and should an Importer do this?
17
MAIN POINTS
Top places to control import data
Parts List
PGA Documentation
Invoices/Line Items
Duties, Taxes, Exam/Port Fees
18
IMPORTER 1 PROFILE NO PGA
100-5000 ENTRIES, AIR/MOST OCEAN
BROKER APPROACH
 Will Price Competitively
 Parts Lists  Accuracy and Time
Efficiency
 Template ISF and Entry Lanes
 Manage Invoice/Line Items
 Easiest to Automate
 Pay Duties, Exam/Port fees
IMPORTER
 Establish ACH PUN, PMS
 Create/Control Parts List
 Control Invoice/Line Item data
 Easiest to Automate
 Leverage Brokerage Pricing
 Filing Options
 Self-File
 Hybrid File
19
IMPORTER 2 PROFILE NO PGA
100-5000 ENTRIES, AIR/OCEAN/N. Border
BROKER APPROACH
 Will Price Competitively
 Parts Lists  Accuracy and Time
Efficiency
 Template ISF and Entry Lanes
 Manage Invoice/Line Items
 Pay Duties, Exam/Port fees
IMPORTER
 Establish ACH PUN, PMS
 Create/Control Parts List
 Control Invoice/Line Item data
 Leverage Brokerage Pricing
 Filing Options
 Self-File
 Hybrid File
20
IMPORTER 3 PROFILE PGA
100-2000 ENTRIES, AIR/MOST OCEAN
BROKER APPROACH
 Can Price Competitively
 Parts Lists  Include PGA data
 Table or Spreadsheet PGA Data
 Template ISF and Entry Lanes
 Automate System above 800 Entries
 Pay Duties, Exam/Port fees
IMPORTER
 Establish ACH PUN, PMS
 Create/Control Parts List
 Understand and Include PGA data
 Leverage Brokerage Pricing
 Filing Options
 Self-File
 Automate Self-Filing, Hybrid
File
 Hybrid File
21
IMPORTER 4 PROFILE PGA
2000+ ENTRIES, AIR/MOST OCEAN
BROKER APPROACH
 Less Pressure to Price Competitively
 Parts Lists  Include PGA data
 Table or Spreadsheet PGA Data
 Template ISF and Entry Lanes
 Automate System Creates Huge Cost
Savings
 Pay Duties, Exam/Port fees
IMPORTER
 Establish ACH PUN, PMS
 Create/Control Parts List
 Understand and Include PGA data
 Leverage Brokerage Pricing
 Filing Options
 Self-File
 Automate Self-Filing, Hybrid
File
 Hybrid File
22
IMPORTER 5 PROFILE PGA
100-5000+ ENTRIES, AIR/ OCEAN/N. Border
BROKER APPROACH
 Less Pressure to Price Competitively
 Parts Lists  Include PGA data
 Table or Spreadsheet PGA Data
 Template ISF and Entry Lanes
 Automate System Creates Huge Cost
Savings
 Pay Duties, Exam/Port fees
IMPORTER
 Establish ACH PUN, PMS
 Create/Control Parts List
 Understand and Include PGA data
 Leverage Brokerage Pricing
 Filing Options
 Self-File
 Automate Self-Filing, Hybrid
File
 Hybrid File
23
THE ROAD AHEAD
Common Themes and Best Practices
24
THE ROAD AHEAD
Common Themes and Best Practices
MAIN POINTS to control import data
PARTS LIST
 Individual Part Numbers
 Associate Number to HTS, CO, MID, PGA, FTA, GSP
PGA DOCUMENTATION
Add to Parts List
 Template or Spreadsheet PGA Documentation
 Immediate updating as new Suppliers are Added
INVOICES, LINE ITEMS
 Purchase Orders
 Implement a Standardized Invoice
 Part Numbers for all Invoices/Line Items
DUTIES, TAXES, EXAM/PORT FEES
Establish your own ACH PUN
Apply for PMS
Easy to get Broker to Pay
25
THE ROAD AHEAD
Common Themes and Best Practices
TAKE CONTROL WHERE YOU CAN
LEVERAGE BROKERAGE PRICING
EXPLORE AND UTILIZE SELF OR HYBRID FILING
 Self-File ISF/Entry
 Outsource Entry
 Self-File Some Entries
 Outsource Complex Lanes
 Automate ISF/Entry Data to Self-File
 Automate ISF/Entry Data to Full Service Broker
26
THE ROAD AHEAD
Common Themes and Best Practices
CUSTOMS COMPLIANCE, EXAMS, FINES/PENALTIES
IMPORTER SECURITY FILING
 Control at the Port Level
 6 Month Compliance Tail
 2O Hold, No ISF on File if within port limits
 Still very manual to have hold removed
 Reduce your Customs Demerits
 To Date, very few fines
 Customs Does Not See your Data Screen
EXAMS
 CBP moving back toward Enforcement
 Expect Higher level of Exams
FINES PENALTIES, ADD/CVD
 ADD/CVD Cases
 Cold Rolled Steel, Aluminum, Wheels
 CF 28 Same
 CF 29 Same
27
THE ROAD AHEAD
Common Themes and Best Practices
EMBRACE THE SINGLE WINDOW
ROLLOUT WILL CONTINUE TO HAVE BUMPS
BUGS WILL CONTINUE TO OCCUR
AGENCIES WILL CONTINUE TO BE ADDED
28
info@3rdwave.co3rdwave.co+1 (416) 510-8800 29
Managing Customs & PGAs
A Total Perspective for Importers
Gregg Cummings,
gregg@strixsmart.com
Edward (Ned) Blinick
Chief Product Officer
eblinick@3rdwve.co

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Managing Customs and PGA = a Total Perspective for Importers

  • 1. info@3rdwave.co3rdwave.co+1 (416) 510-8800 1 Managing Customs & PGAs A Total Perspective for Importers Edward (Ned) Blinick Chief Product Officer A Q&A with Gregg Cummings, Managing Partner, Strix LLC eblinick@3rdwave.co
  • 2. 2 About Gregg Gregg has more than 25 years of experience in the International trade industry and Corporate Finance. He is a Managing Partner of STRIX, LLC a leading company in Self- Filing Software, International Freight, Domestic Trucking and Logistics. He is also the President of TBI Brokers, Inc., the firm's Customhouse Brokerage. Gregg is recognized as an expert in the area of customs automation for ISF and Entry filing and provides important consulting services to companies who seek to bring processes in house as well as marrying full service brokerage automation and hybrid solutions. He is an active member of the International Compliance Professionals Association (ICPA) and speaks frequently on the topics of how importers can streamline their import processes via automation and internal control.
  • 3. AGENDA WONDERFUL WORLD OF ACE Changes, challenges, Opportunities PGAs complex challenges Gaining Competitive Advantages TRADITIONAL ROLES OF CBP, IMPORTER, BROKER Historically and Today Flexibility and Control of Data IMPORTER CASE STUDIES Brokers point of view Importers point of view THE ROAD AHEAD Best practices Current regulatory environment
  • 4. 4 Unique position in marketplace Full Service Customs Broker Cloud based Self-Filing Solution Formerly
  • 5. 5 The ACE environment forever changes the relationship between CBP and the Importer This is a positive and needed direction Single Window makes sense for todays technology PrePost
  • 6. 6 Changes mean Challenges Challenges mean Opportunities Opportunities mean Competitive Advantages
  • 7. 7 What are the Main Changes Entry Summary Cargo Release PGAs CEEs
  • 8. 8 The Main Challenges ACE Entry Summary ACE Cargo Release ACE System Downtime ACE System Message sets
  • 9. 9 PGAs remain the Complex Challenge of ACE FDA APHIS DOT EPA
  • 10. 10 Opportunities begin by exploring the Traditional Roles between CBP, the Importer and the Broker Complex challenges always provide Opportunities
  • 11. 11 CBP Roles and Responsibilities Complex challenges always provide Opportunities Then: US Customs Reported to Treasury Collect Duties and Fees Enforcement Collect Trade Data, Census information Now: Homeland Security Security, Enforcement Pendulum Swing back to more traditional enforcement
  • 12. Complex challenges always provide Opportunities Customs Brokers Roles and Responsibilities Then Primary interface between Importer and Customs Oversight of Import Clearance Collate Documentation Classify goods Communicate to Ports Full Service Now Not Necessarily primary interface with Customs Tougher legal and Regulatory Environment Greater push/pull for Importer to Classify Greater push/pull for Importer to Collate Docs
  • 13. Traditional Roles of Importer Complex challenges always provide Opportunities Then Relied on Broker to provide Service Interface with Customs Process a Mystery Visibility Limited Penalties for non-Compliance High Now Todays Technological and Legal Environment Process a Mystery no longer ACE Portal Importer provides most documentation Importer classifies goods Must audit ISF and Entry files Visibility on par with Broker
  • 14. 14 Are you in Control or Out of Control? Todays Importer has greater Flexibility and Options than ever before Lower Pricing for Brokerage Options to Self-File Options to Hybrid File Automation Automate Self-Filing Automate Brokerage
  • 15. 15 Its The Data Stupid!
  • 16. 16 Controlling the Process begins by Controlling the Data Importer Case Studies How does a Broker do this? How can and should an Importer do this?
  • 17. 17 MAIN POINTS Top places to control import data Parts List PGA Documentation Invoices/Line Items Duties, Taxes, Exam/Port Fees
  • 18. 18 IMPORTER 1 PROFILE NO PGA 100-5000 ENTRIES, AIR/MOST OCEAN BROKER APPROACH Will Price Competitively Parts Lists Accuracy and Time Efficiency Template ISF and Entry Lanes Manage Invoice/Line Items Easiest to Automate Pay Duties, Exam/Port fees IMPORTER Establish ACH PUN, PMS Create/Control Parts List Control Invoice/Line Item data Easiest to Automate Leverage Brokerage Pricing Filing Options Self-File Hybrid File
  • 19. 19 IMPORTER 2 PROFILE NO PGA 100-5000 ENTRIES, AIR/OCEAN/N. Border BROKER APPROACH Will Price Competitively Parts Lists Accuracy and Time Efficiency Template ISF and Entry Lanes Manage Invoice/Line Items Pay Duties, Exam/Port fees IMPORTER Establish ACH PUN, PMS Create/Control Parts List Control Invoice/Line Item data Leverage Brokerage Pricing Filing Options Self-File Hybrid File
  • 20. 20 IMPORTER 3 PROFILE PGA 100-2000 ENTRIES, AIR/MOST OCEAN BROKER APPROACH Can Price Competitively Parts Lists Include PGA data Table or Spreadsheet PGA Data Template ISF and Entry Lanes Automate System above 800 Entries Pay Duties, Exam/Port fees IMPORTER Establish ACH PUN, PMS Create/Control Parts List Understand and Include PGA data Leverage Brokerage Pricing Filing Options Self-File Automate Self-Filing, Hybrid File Hybrid File
  • 21. 21 IMPORTER 4 PROFILE PGA 2000+ ENTRIES, AIR/MOST OCEAN BROKER APPROACH Less Pressure to Price Competitively Parts Lists Include PGA data Table or Spreadsheet PGA Data Template ISF and Entry Lanes Automate System Creates Huge Cost Savings Pay Duties, Exam/Port fees IMPORTER Establish ACH PUN, PMS Create/Control Parts List Understand and Include PGA data Leverage Brokerage Pricing Filing Options Self-File Automate Self-Filing, Hybrid File Hybrid File
  • 22. 22 IMPORTER 5 PROFILE PGA 100-5000+ ENTRIES, AIR/ OCEAN/N. Border BROKER APPROACH Less Pressure to Price Competitively Parts Lists Include PGA data Table or Spreadsheet PGA Data Template ISF and Entry Lanes Automate System Creates Huge Cost Savings Pay Duties, Exam/Port fees IMPORTER Establish ACH PUN, PMS Create/Control Parts List Understand and Include PGA data Leverage Brokerage Pricing Filing Options Self-File Automate Self-Filing, Hybrid File Hybrid File
  • 23. 23 THE ROAD AHEAD Common Themes and Best Practices
  • 24. 24 THE ROAD AHEAD Common Themes and Best Practices MAIN POINTS to control import data PARTS LIST Individual Part Numbers Associate Number to HTS, CO, MID, PGA, FTA, GSP PGA DOCUMENTATION Add to Parts List Template or Spreadsheet PGA Documentation Immediate updating as new Suppliers are Added INVOICES, LINE ITEMS Purchase Orders Implement a Standardized Invoice Part Numbers for all Invoices/Line Items DUTIES, TAXES, EXAM/PORT FEES Establish your own ACH PUN Apply for PMS Easy to get Broker to Pay
  • 25. 25 THE ROAD AHEAD Common Themes and Best Practices TAKE CONTROL WHERE YOU CAN LEVERAGE BROKERAGE PRICING EXPLORE AND UTILIZE SELF OR HYBRID FILING Self-File ISF/Entry Outsource Entry Self-File Some Entries Outsource Complex Lanes Automate ISF/Entry Data to Self-File Automate ISF/Entry Data to Full Service Broker
  • 26. 26 THE ROAD AHEAD Common Themes and Best Practices CUSTOMS COMPLIANCE, EXAMS, FINES/PENALTIES IMPORTER SECURITY FILING Control at the Port Level 6 Month Compliance Tail 2O Hold, No ISF on File if within port limits Still very manual to have hold removed Reduce your Customs Demerits To Date, very few fines Customs Does Not See your Data Screen EXAMS CBP moving back toward Enforcement Expect Higher level of Exams FINES PENALTIES, ADD/CVD ADD/CVD Cases Cold Rolled Steel, Aluminum, Wheels CF 28 Same CF 29 Same
  • 27. 27 THE ROAD AHEAD Common Themes and Best Practices EMBRACE THE SINGLE WINDOW ROLLOUT WILL CONTINUE TO HAVE BUMPS BUGS WILL CONTINUE TO OCCUR AGENCIES WILL CONTINUE TO BE ADDED
  • 28. 28
  • 29. info@3rdwave.co3rdwave.co+1 (416) 510-8800 29 Managing Customs & PGAs A Total Perspective for Importers Gregg Cummings, gregg@strixsmart.com Edward (Ned) Blinick Chief Product Officer eblinick@3rdwve.co