Presentation: CEE Chemicals. By Michael Ford, VP Regulatory Compliance and Quality, BDP International. Global Logistics & Transportation Solutions

Transcription

1 Presentation: CEE Chemicals By Michael Ford, VP Regulatory Compliance and Quality, BDP International

2 Centers of Excellence and Expertise

3 Pharmaceutical / Chemical Industry Integration Center CBP has established 4 Centers The Pharmaceuticals and Chemical Center in New York The Electronics Center in Los Angeles The Petroleum & Natural Gas Center in Houston Aerospace and Automotive in Detroit Center Organization Center Directors report to Directors, Field Operations Interdisciplinary Staff

4 Increase Industry Based Knowledge Interact with relevant other government agencies to understand their processes and the impact on trade Regular communication with internal and external stakeholders Serve as primary point of contact for trade and CBP personnel for industry-related issues Develop national policy to address industry-specific issues Industry-led training Training sessions with Trade on business process Trade training on identifying counterfeits (Enforcement) Engage with small and medium-sized importers

5 Objectives, Enforcement and Goals

6 Goals Increase industry based knowledge within the agency Facilitate legitimate trade for designated traders within the industry through risk segmentation Focus on enforcement to address risk associated within the industry

7 Facilitate Legitimate Trade Collaborate with other government agencies to develop alternatives to paper-bound requirements Analyze imports by industry and segment risk Integrate trade targeting efforts by industry to reduce exams and expedite cargo release Remove impediments to enable pre-arrival release for trusted traders Monitor cargo release for trusted traders and work with the Ports to resolve holds Process post-release documentation (or its electronic equivalent) for trusted traders Manage and perform ISA oversight for trusted trader accounts Work with importers to move them into a trusted trader status Monitor and resolve uniformity issues and systemic barriers

8 Enforcement Risk Management Fully employ the use of risk management and targeting to detect and deter trade non-compliance and apply consistent enforcement actions Focus the bulk of Officer and Import Specialist resources on known and unknown high-risk shipments, while devoting a smaller cadre of employees to manage CBP's trusted, low-risk importers Identify and target critical points in the import life cycle where product safety risks are greatest to protect consumers from health and safety concerns Develop pinpoint targeting and special enforcement operations in conjunction with other government agencies

9 Current State

10 Background Responding to the Call for Trade Transformation In direct response to calls for more uniform and efficient facilitation, and in collaboration with the Commercial Operations Advisory Committee (COAC) during FY 2011 CBP created two pilots The resulting pilots underwent careful concept testing and validation both within CBP and with the broader trade community CEE and AE Pilots The Center of Excellence and Expertise (CEE) pilot was established in November 2010 to enhance facilitation, improve enforcement efforts, and increase CBP's knowledge of the pharmaceutical industry

11 Background (continue) The Account Executive (AE) pilot was established to work with selected trusted partners in the electronics industry to facilitate trade, while ensuring continued compliance with all import requirements Both pilots relied on small cross-occupational core teams, with matrix staff bringing additional specialized expertise Expanded Centers At the conclusion of the pilots, the AE concept was combined with the CEE to create new Centers to segment risk, facilitate trade for trusted partners and develop comprehensive enforcement strategies - making CBP s haystack smaller Future expansion is expected to result in nine centers that will cover the full range of imports

12 Trade Transformation! CBP has issued a FRN on August 28, 2012, announcing test of Decision making Authority for the CEEs. CBP is seeking companies that may wish to test the new CEE s for entry summary and post entry transactional actions. All companies will need to submit an application to participate in the test Voluntary

13 Current State Action Eliminates unnecessary transactional work from compliant imports Port of entry shifts work to highrisk shipments Single point of contact Cross-functional expertise Benefits Fewer cargo delays Reduced costs/greater predictability More complex enforcement work improved enforcement results Improved relationship with CBP Increased uniformity and transparency Environment for in-depth learning to increase CBP expertise

14 What will (not) Change?

15 Test what will change Entry summary details will be routed to the CEE for processing, functions to be processed Duty refunds Requests for Computed value 28 s & 29 s Extensions / Suspensions of Liquidations Protests and error corrections, includes Census resolutions The CEE s will not handle Cargo release function will remain at Port of Entry

16 Test what will not change The following functions will not change when testing the CEE processes Quota entries Bulletin notices of Liquidation Discrepancies of duties Requests for further review RLF filings & EIP

17 Application To participate in the test All importers must submit a letter or a request to CBP- all present participating members still must apply Eligibility requirements Chemicals classified under 2801 through 2935,2938, 2940, 2942, 3101 through 3302, 3402 through 3405, 3407 through 3604, 3606 through 3817 and 3819 through 3825 Be enrolled in C-TPAT & a Member of ISA will be given priority status for the test If not ISA, still apply for the test

18 Status September 2012 Centers will transition entry summary processing by the following date Pharmaceuticals, Health and Chemicals September 27, 2012

19 Conclusion

20 Last words The CEE will change the current processes that have been designed for the past 20 plus years Account Management for importers will become a reality Importers and Brokers will need to work together to manage situation ( holds, exams etc ) to keep the speed of delivery in place and keep the costs in place. In the coming future will exports become part of the design?

21 Contact Information Pharmaceutical Center 1 Penn Plaza, Suite 1013 New York, NY CEE-Chemicals@cbp.dhs.gov

22 Department of Homeland Security Customs and Border Protection Pharmaceutical Industry Integration Center One Penn Plaza New York, NY 10119

23 Presentation: CEE Chemicals By Michael Ford, VP Regulatory Compliance and Quality, BDP International