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 1 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. PAGE 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) ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ 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: ● ● ● ● ● ● 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 3 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 ❒ ❒ ❒ ❒ ❒ 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 PAGE 5 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- PAGE 6 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 7 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 7 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 8 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