Who is the IOR? Importer of Record
One of the most common questions asked within our initial consultation with clients is, who is the IOR? The Importer of Record (IOR) is the essential entity in international trade. It is the one who is responsible for complying with all customs regulations, facilitating smooth import operations and managing all potential legal liabilities. It is essential when conducting due diligence and avoiding penalties.
Ahh Coffee
About $10 billion in coffee was imported into the U.S. in 2022 with 50% primarily coming from Brazil and Columbia at roughly $2.2 billion each. It’s a staple in the majority of American’s daily lives via a kick of caffeine in the morning. The amount of business discussed daily over numerous cups of java goes without saying. If you’d like to have a cup with us and have a chat about anything international trade compliance related, we’ll be here. BLG can help you with Global Trade Compliance.
Superhero Updated
Chess Match
In the world of international trade not all regulations seem to be in black and white as there is some grey area. But if you choose to play a chess match with customs, based on our experience you stand a good chance of self-destructing. Global Trade Compliance is what we do.
CTPAT
Customs Trade Partnership Against Terrorism is about building supply chain security and mitigating risk. CTPAT is an ever-evolving security program that was inaugurated by Customs and Border Protection in 2001 under the newly establish Department of Homeland Security. Today is is a multi-layer cargo strategy that works with the trade community to support and strengthen international supply chains. There are at least a dozen benefits to the program including reduced number of CBP examinations, front of the line inspections, shorter wait times at the border, possibility of enjoying additional benefits by being recognized as a trusted trading partner by foreign customs administrations that have signed a Mutual Recognition Agreement with the United States, eligibility for other U.S. government pilot programs such as the FDA’s secure supply chain program, priority consideration at CBP’s industry focused Centers of Excellence and Expertise, the best approach is to have a guide assist int he process of applying for entrance into the program and we just happen to have a CTPAT expert on campus.
Bananas
WIth regard to import and export, bananas are botanical berries not fruit. The HTS code for berries is different from that of bananas which is different from the HTS code for edible fruit in general. If you need help with classification BLG can assist.
USMCA GURU
Of the 21 FTAs (Free Trade Agreements) that the U.S. currently has in place none is more significant than USMCA (formerly known as NAFTA). The benefits of participation can be substantial. If you need some assistance in qualifying your merchandise, BLG has USMCA Gurus (formerly known as NAFTA Gurus) on campus. Jim Holbein, D.C. counsel for Braumiller Law Group, even helped negotiate the original NAFTA agreement. Our mantra is rooted in success, drawing from decades of experience.
AI
We would like to go on the record and state that AI will not be replacing any of our attorneys in the near future. Well maybe a few by 2050 as some will be 80 years old by then. Keep in mind they will have learned everything they know from us. So they, for all intents and purposes, are us. Maybe we could all eventually just go on vacation and let our AI’s do all the work. On second thought, they are really still just infants in the machine, ever evolving but still infants. Keep in mind the next time you engage with your favorite AI app for legal advice. BLG will be here if you need us, or possibly at the beach with cell service.
FTZs
The U.S. foreign-trade zones program was created by the Foreign-Trade Zones Act of 1934 during President Franklin D. Roosevelt’s administration. It was amended in 1950 under Harry S. Truman’s administration and really came into play with global trade in 1984 under the Reagan administration. Today, there are over 230 foreign-trade zone projects and nearly 400 sub zones in the United States, all within or adjacent to the ports of entry. Every state has at least one port of entry, and there are 314 ports of entry categorized by 19field operations offices which they report to. These FTZs are there to eliminate and/or reduce tariff burdens on the importation of foreign inputs and on exported finished products. The cost savings can be substantial relevant to: duty exemption, duty deferral, duty reduction, invited tariff, merchandise processing fee, streamlined logistics, quota avoidance, and direct delivery. BLG has experts regarding the establishment and administration of FTZs.
So You Just Hit a Wall
You discovered a wrong classification on product in the supply chain and you must decide whether or not to file a Prior Disclosure. If you go down this road, you’d better keep your friends and employees close and your enemies even closer because there is a nice size cash reward via customs for whistleblowers. If they find out, it’s classified as intentional, and the penalties are now multiplied by 10x the original amount. Why not come clean and use the Prior Disclosure as the mitigation tool that it was meant to be. You’ll sleep better anyway. BLG can help with Prior Disclosure which we file on a regular basis. Global Trade Compliance is what we do.