Ken Hamanaka Co Newsletter: August, 2019



The announcement last week by President Trump and USTR Lighthizer of increases to the four lists of HTS numbers for China Section 301 duties is set for publishing in the Federal Register. You can click the button below for the text published on the USTR’s website. Remember that the most important things are that lists 1, 2 and 3 increase to 30% from 25% effective October 1st and lists 4A and 4B which were slated to begin on September 1 and December 15, respectively, increase to 15% from their previously announced 10%.



As supply chains are moving as quickly as possible to diversify away from China because the trade war and escalating duties show no signs of abating, CBP is repeatedly and sternly cautioning importers to be on the lookout for illegal transshipments, particularly from neighboring Vietnam.

Transshipment is the moving of cargo from one country of manufacture to another and falsely declaring the country of origin. CBP has said, both in writing and in person, that compliance programs should include factory checks and verifications that cover not only country of origin, but to ensure that neither forced labor or child labor is used – both of which are violations of US law. 

CBP in mid-August released a Notice of Proposed Rulemaking (NPRM) that floats the notion of additional verifications for customs brokers on individual and corporate importers of record. The agency views customs brokers as being integral to facilitating legitimate trade and as the first line of defense against criminal activity and fraud.  Among the changes proposed by CBP are a new requirement that a broker must obtain documentary proof (driver’s license, passport) of the identity of the grantor of a power of attorney authority.

Comments are due to the agency by October 15th and the Federal Register notice is linked to the READ MORE button below.



Next month, the International Chamber of Commerce will release an update to their widely published and accepted Incoterms (R), the essential guidepost for who pays what in an international transaction. These changes take effect on January 1, 2020, and are applicable to importers and exporters alike and should be reviewed and used during negotiations with a buyer or seller. The Incoterms(R) are copyrighted and we cannot provide a copy of them when they become available, but the ICC has them available for sale on their website. For more information about Incoterms and to pre-order your copy, click below. 



In observance of the American Labor Day holiday, we are closed on Monday, September 2nd and will return to the office on Tuesday, September 3rd. We wish everyone celebrating the traditional “end of summer” a very safe holiday weekend.

Copyright © 2019 Ken Hamanaka Co Inc/Crosswinds Intl Inc, All rights reserved.

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