January 2009

Transcription

January 2009
ORGANIZER ISSUE
VIEW
Global View is published by:
Rogers Worldwide
1550 E. Higgins Road, Suite 106
Elk Grove Village, IL 60007
Contact:
Jeanette Mucha, LCB
Director National Sales
Tel: (847) 806-9200
Mobile: (847) 970-8017
jmucha@rerogers.com
YOU TRAVEL THE WORLD WITH YOUR BUSINESS.
WE MAKE SURE YOUR EXHIBIT DOES TOO.
Packing List
10 + 2 ....................................................................1
Blatant and Gratuitous Promotion ......................4
Servicing International Exhibitors ........................5
The Lacey Act: Should you be scared
or prepared? ..........................................................6
Editor:
Michelle Bruno,
CMP, CEM
Tel: (801) 520-0797
michelle@brunogroup.com
JANUARY
2009
What are you working on? ..................................8
Understanding
the 10 + 2
Initiative:
Partnering with exhibition
experts to expedite
international clearances
B
eginning January 26, 2009, exhibition
organizers will be looking to U.S.
Customs brokers to assist their international exhibitors with new importation
requirements. In an effort to tighten security at the nation’s ports, U.S. Customs and Border
Protection (CBP) will begin implementing new clearance procedures that require additional information
CONTINUED ON PAGE
2
PAGE
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10+2 (cont’d from page 1)
Ten data elements will be required from the
importer and two data elements will be required
from the carrier within a tight time frame.
from exhibitors, their supply chain partners
and freight carriers before clearance is granted. Because foreign shipments destined for
U.S. tradeshows often require special handling, international organizers are partnering
with exhibition experts to streamline the
process and expedite clearances.
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2
According to the “Importer Security
Filing and Additional Carrier Requirements”
Interim Final Rule (docket number: USCBP2007-0077) also referred to as the 10 + 2
Initiative, “the required information is reasonably necessary to improve CBP’s ability
to identify high risk shipments so as to prevent smuggling and ensure cargo safety and
security.” Ten data elements will be required
from the importer and two data elements
will be required from the carrier (see figure
1) within a tight time frame (usually 24
hours) prior to departure and/or arrival.
Some of the information being requested
is new. For example, three of the data elements required from the importer have not
been previously requested including:
● Name and address of the first party to
physically receive the goods after release
from U.S. Customs
● Name and address of the location where
the goods were actually packed for
transport in the final country of
exportation
● Name and address of the company that
packed the goods prior to loading on
the carrier in the final country of exportation
Figure 1
Ten Data Elements Required
from Importer
❒ 1. Manufacturer (or seller)
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❒
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name and address
2. Seller name and address
3. Buyer name and address
4. Ship-to name and address
5. Container stuffing location
6. Consolidator (stuffer)
name/address
7. Importer identification
number
8. Consignee identification
number
9. Country of origin
10. U.S. harmonized tariff
number
Two Data Elements
Required from Carrier
❒ 1. Vessel stow plan
❒ 2. Container status message
In the context of international exhibition
importations, identifying the importer of
GLOBAL VIEW ★ INTERNATIONAL EXHIBITION ORGANIZERS, MEETING PLANNERS AND CONFERENCE PRODUCERS
10+2 (cont’d from page 2)
record is a frequent point of discussion. First
time exhibitors and those that have not
established buyer networks are often at a disadvantage because they have no official
importer of record to designate. The
importer is liable for all duties (secured by a
surety bond) and compliance with all statutory and regulatory requirements resulting
from importation of the goods for the show.
It is necessary for these companies to designate a U.S. representative or a licensed customs broker for this purpose.
The geo-political climate of the world
has increased the complexity of international
transportation logistics. While the modes of
transportation remain the same, the
procedures and regulations that govern
trans-border shipping, coupled with heightened security requirements such as the 10 +
2 Initiative, highlight the need for expertise
in this area. Designating an experienced
international exhibition logistics company
that is also a licensed customs broker, as an
official show contractor, offers organizers
and their international exhibitors a number
of important benefits:
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Licensed customs brokers to facilitate
compliance with new regulations
Streamlined door-to-show site
transportation and clearance procedures
Designation of the customs broker as
the importer of record
Posting of the required surety bond to
guarantee payment of duties
Single point of contact for organizers
and exhibitors
Clearance at show site for late shipments
The 10 + 2 regulations are currently in
an interim phase in which public comments
are being solicited until January of 2010.
Until then, CBP will attempt to remain flexible on some aspects of compliance. With
new administrators at the helm in
Washington, observers are keeping a close
eye on feedback from the international trade
community. When the testing phase is completed, the new regulations will become permanent with penalties possible of up to
$5,000 per violation.
RESOURCES
Legal Counsels and Educators:
Melissa Miller Proctor
Sandler, Travis & Rosenberg and
Glad & Ferguson
Tel. (949) 274-1428
Email:mproctor@strtrade.com
Laura Siegel Rabinowitz
Sandler, Travis & Rosenberg, PA
Tel. (212) 883-1300
Email: lsrabinow@strtrade.com
READ MORE
Customs and Border Protection
http://www.cbp.gov/xp/cgov/trade/cargo_security/carriers/security_filing/
JANUARY
2009
PAGE
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Rogers Worldwide Re-launches Global
View Newsletter…
Rogers Worldwide re-launched its
newsletter Global View, to help keep clients
abreast of the many changes in transportation and customs clearance logistics. The
monthly publication, which kicks off in
January 2009, will alternate its focus each
month between international organizer and
exhibitor-related issues. The newsletter will
be distributed via email and on the Rogers
Worldwide website at www.rerogers.com.
Rogers Worldwide Import Services Offers
On Site Show Clearances…
Rogers Worldwide Import Services
(RWIS), a division of Rogers Worldwide,
has completed its testing phase for clearing
international exhibition shipments at show
site electronically. RWIS is a federally regisPAGE
4
tered customs brokerage with authority to
file remote electronic entries in any U.S.
port. Exhibitors with international shipments that have copies of the commercial invoice, packing list and bill of
lading may contact Rogers
Worldwide on show site to effect
clearance. There are some limitations, however. Only permanent entries (duty paid) can be
cleared remotely. The RWIS
license does not cover specialized goods such as food or those under temporary import or ATA Carnet. In addition,
upcoming regulation changes such as 10 + 2
and the Lacey Act Amendments may make
on site clearances more difficult
Rogers Worldwide Office Celebrates
Four Years in Business…
December 2008 signaled the completion
of four years since Rogers Worldwide
opened its office in Las Vegas. The capitol of
glitter, glitz and glamour is also one of the
top tradeshow destinations in the world.
Sherri
Pelc,
a
licensed
customs
broker (LCB), formerly of Detroit-based
brokerage firm A.N. Derringer, opened the
office in 2004 to accommodate a growing
portfolio of exhibitions that include the
Kitchen and Bath Industry Show (KBIS),
Shot Show, National Hardware Show, ISC
Expo, International Sign Association Show,
Sherri Pelc (right) and colleague
Courtney Chase prepare to ring in the
New Year and the beginning of year five of
the Rogers Worldwide Las Vegas office.
Rogers Worldwide Las Vegas is
a full service office offering international exhibition logistics and customs
clearance services for clients with
shows west of the Mississippi River.
Sherri Pelc, LCB
Rogers Worldwide,
div. of Rock It Cargo USA LLC
P:
702-642-3575 F: 702-648-6968
Efax: 928-438-6481 C: 702-408-6481
www.rerogers.com
www.rockitcargo.com
Global Gaming Expo and other Tradeshow
200 Exhibitions.
GLOBAL VIEW ★ INTERNATIONAL EXHIBITION ORGANIZERS, MEETING PLANNERS AND CONFERENCE PRODUCERS
Servicing
International Exhibitors
L
ooking for ways to attract and
retain international exhibitors?
Here is Global View’s Idea of the
Month: Create a dedicated web
page or micro-site exclusively for
international exhibitors. Include the following features:
❒ Exhibitor registration forms
❒ Information on obtaining a visa such as
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application form, location of embassy and
consular offices worldwide, letters of invitation from show management
Information on working with a general
service contractor and labor unions
Instructions for shipping and
customs clearance including forms and
updates on new U.S. customs regulations
Directory of local ethnic
restaurants
Maps and information on local transportation services such as trains, taxis,
public transportation and private car
services
List of foreign language
interpreters
JANUARY
2009
Create a dedicated web page or
micro-site exclusively for international
exhibitors.
Click on the links below to view these dedicated web pages.
National Association of Broadcasters Show
http://www.nabshow.com/2009/exhibitServices/international.asp
International Builder’s Show
http://www.buildersshow.com/Home/Page.aspx?pageID=9
Consumer Electronics Show
http://www.cesweb.org/international/services.asp
BookExpo America
http://www.bookexpoamerica.com/en-us/741.cfm
International Security Conference and Exposition West
http://www.iscwest.com/app/homepage.cfm?appname=180&moduleID=295
9&LinkID=24765
❒ Location of local foreign embassies and
consular offices
❒ Location of international exhibitor service
areas on the show floor
❒ Designated show contact person for
questions
❒ Personal safety information and use of the
911 emergency call system
❒ List of show sales offices and
representatives around the world
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The Lacey Act:
Should you be scared
or prepared?
E
nforcement of some of the
most sweeping import regulation changes in recent history
may come as early as April 1,
2009 and no category of exhibition is immune. What were intended as
strict measures to curb illegal logging
because of its contribution to the loss of biodiversity, increased sedimentation, climate change and
environmental degradation, have evolved into
unwieldy reporting requirements that many international
exhibitors may find too difficult, too costly or not
worth the effort to comply
with. Organizers offering
accurate information and
logistical support can help
their international clients
avoid costly delays and
noncompliance penalties.
In the Food, Conservation and Energy Act of 2008,
amendments to the hundred-
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year-old Lacey Act became law, making it
unlawful to import, export, transport or possess any goods in violation of plant protection laws of the U.S., Indian Tribes or any
foreign country. In order to enforce the law,
importers are required to document the scientific name of the plant (genus and species),
quantity of the plant and name of the country from which the plant was harvested.
Under the amended Lacey Act, “plant” is
defined as “any wild member of the plant
kingdom including roots, seeds, parts or
product thereof, and including trees from
either natural or planted forest stands.”
While there are some exemptions to the
reporting requirements such as
packaging (when included with
the product), “common cultivars and common food crops”
(as yet undefined by regulators), scientific
specimens for lab testing and plants that are
to remain planted or to be planted or
replanted, nearly every category of product
(85 of the 97 chapters of the U.S.
Harmonized Tariff Schedule) is affected.
This includes anything containing a plant
product from a wood button on a sweater to
pharmaceuticals, cars, textiles, food products, furniture and paper. It also includes
products that are accompanied by instruction
manuals (including electronics and appliances) or that have paper or fabric hangtags
or content labels.
Severe civil and criminal penalties have
turned up the heat on the compliance conversation. Violations of the Lacey Act provisions can result in civil and/or criminal penalties for importers such as fines and imprisonment as well as forfeiture of the merchandise.
Legal experts have estimated potential fines
from $20,000 to $250,000 and prison terms
from one to five years per violation. For an
international exhibitor with a 10 x 10 foot
booth, for example, the risk may be too
great. Imported display properties are subject to compliance and last minute shipments
from unknown or unverifiable suppliers will
be unable to clear customs.
Implementation of the Lacey Act provisions remains a challenge for government
agencies. The Animal and Plant Health
CONTINUED ON PAGE
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GLOBAL VIEW ★ INTERNATIONAL EXHIBITION ORGANIZERS, MEETING PLANNERS AND CONFERENCE PRODUCERS
Lacey Act (cont’d from page 6)
Inspection Service (APHIS) of the U.S.
Department of Agriculture is tasked with
implementing the revised Lacey Act provisions in conjunction with a larger interagency group composed of representatives
from the U.S. Forest Service, Customs and
Border Protection (CBP), U.S. Trade
Representative (USTR), U.S. Department
of Justice, U.S. Department of State, U.S.
Fish and Wildlife Service (FWS), Council on
Environmental Quality and the Department
of Commerce.
Because of the involvement of so many
regulatory groups, a number of questions
regarding implementation of the provisions
remain. A lead agency has not been designated to head up enforcement. Because each
agency will interpret compliance through it’s
own lens of procedures and provisions, multiple violations may occur for the same
offense. Several clarifications such as the definition of “common cultivars and common
food crops” and how quantities will be
reported on the declaration form are anticipated, but have not been provided. The proposed declaration form is currently only
available in paper format with electronic filing procedures forthcoming on or before
April 1 when enforcement is scheduled to
commence.
As with any new regulations, changes are
inevitable. A recent letter from members of
Congress to representatives of the international trade community offered some hope
iterating that Congress intends that there be
a “common sense application of the regulations,” and “agencies can significantly curb
trade in illegal plants without disrupting
legitimate trade.” Meanwhile exhibition
organizers can help prepare international
exhibitors by posting relevant information
on their web sites, including updates in
exhibitor newsletters and referring exhibitor
questions to the show’s official freight
forwarder and customs broker.
READ MORE
USDA, Animal and Plant Health Inspection Service
http://www.aphis.usda.gov/plant_health/lacey_act/index.shtml
JANUARY
2009
Under the amended
Lacey Act,
“plant” is defined as “any
wild member of the plant
kingdom including roots,
seeds, parts or product
thereof, and including trees
from either natural or
planted forest stands.”
RESOURCES
Legal Counsel and Educator:
Susan Kohn Ross
Mitchell, Silberberg and Knupp LLP
Tel: (310) 312-3206
Email: skr@msk.com
PAGE
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What are you
working on?
“We just created an online
International Exhibiting Tips
Booklet to help exhibitors deal
with the challenges of global
trade shows and events. The
booklet contains information
and “how-to” tips we've learned
through our 20+ years in the exhibit and events
industry, including trade fair and stand information for the top ten countries where companies
exhibit as well as cultural etiquette and business
negotiation tips. For a free copy of the book, go
to http://www.cepexhibits.com/support/contactus.php. And please keep CEP in mind for your
future design needs and quotes on custom or
rental booths.”
Each month, Global View will highlight international
exhibition industry thought leaders who answer the
simple question, “What are you working on?”
Here’s what’s going on at
Creative Expos and Conferences, a
full-service Walpole, MA-based
organization that develops and helps
produce conferences, trade shows,
expositions, seminars and special
events in North America, Asia,
Europe, Latin America and the Middle East:
“Creative Expos and Conferences is working with the
SEMI Association to launch their Solarcon show in
India. The announcement was made last week in India
and the response has been very well received. The location will not be New Delhi or Mumbai but an up and
coming location: Hyderabad. This city is home to
HITEX, the most modern convention center and HICC,
the most modern conference center in India. SEMI chose
Hyderabad because it houses the biggest concentration of
solar developments in the country. The show will take
place in the fall of 2009.”
Cherif Moujabber, President
Creative Expos and Conferences
www.creative-expos.com
PAGE
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Noel Hoekstra, Director of International
Accounts, CEP International
One of the fastest developing
cities in India, Hyderabad,
population of 8 million, has
become a preferred conference
venue in India.
“We
are
pleased to add
Russia as the
25th participating country to the International Home +
Housewares Show’s gia (Global Innovator Award)
program. Geared to attract the crème de la crème
of worldwide housewares retailers (buyers) to the
Show, the award program continues to increase
the global stature of the Show and is a highly effective way to solidify close, long-term global trade
media relationships. To learn more about gia go to
www.housewares.org/gia.”
Noelle Kull, Account Supervisor,
H+A International, Inc.
GLOBAL VIEW ★ INTERNATIONAL EXHIBITION ORGANIZERS, MEETING PLANNERS AND CONFERENCE PRODUCERS