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On October 18th, the United States put into effect additional duties on aircraft from the European Union as well as on a host of consumer products such as food, alcohol and apparel. These duties on approximately $7.5 billion in imports stem from a decision by the World Trade Organization on illegal subsidies to Airbus SE from the European Union. American importers are feeling the first pinch, but American exporters may be next because a similar case brought by the EU against the USA for subsidies to Boeing may be similarly decided. We've written more about it on our blog - just click below for the link.
CTPAT program changes effective January 1, 2020
Companies who are members of the Customs-Trade Partnership Against Terrorism (CTPAT) program should be aware of changes to the minimum security criteria that are effective beginning January 1, 2020. The changes include additional items like more things to be checked for container safety and security.

CBP has not put these changed items out on their public CTPAT page. Member companies need to log into their CTPAT portal accounts - we've set the button below to go there - to read and download the new MSC's which cover all member company types in the program.
Coppersmith will be at IPATA in Chicago November 1 - 5
Coppersmith Global Logistics is very excited to both be attending and sponsoring the upcoming International Pet Air Transport Association 40th conference in Chicago. This year alone we have been proud to have cleared arriving pets on more than thirty airlines in the United States. Coppersmith are also the nominated customs broker for both American Airlines and United Airlines. If you're planning to be at IPATA, drop Bud an email and we look forward to seeing you at the Hyatt Regency in Chicago.
US / China tariff war updates
The US and China continue to talk with an eye to attempting to reach some sort of agreement in time for the annual APEC summit which is scheduled to be held in Santiago, Chile, next month. Here is a brief summary of the latest updates:

  • The US government has published the process for companies to request an exclusion from List 4a. The portal, http://exclusions.ustr.gov, opens at noon ET on Thursday, October 31st. Submissions can be made through January 31, 2020 at 11:59 PM ET. For the full Federal Register notice, click here.
  • There is a worry that if China relaxes import duties on US agricultural exports, the inland logistics required to get bulk loaded containers to market won't be able to keep up. If a deal is reached, agriculture exporters “will be drinking water from a firehose. It will put a huge burden on everything in logistics from chassis to containers,” Don Lake, senior vice president of enterprise development at Dunavant Logistics Group, said at JOC’s Inland Distribution conference. The Chinese “can buy a lot of cotton in three months and expect to have it in three months.”
  • The December 15th planned imposition of 15% additional duty on List 4b remains on the table as a negotiating point.

At Coppersmith, we're staying on top of these announcements and have aggregated them on a single page covering China 301 updates and activities. Use the button below to bookmark it and visit for the latest information.
Coppersmith sent three of our team members to attend an industry event in California this month that provided us with a host of information about not only what is important to the government agencies which regulate importers and exporters, but also best practices which we are investigating to establish internally. One area that CBP was emphatic about mentioning - and we've been seeing and hearing it throughout the year - is forced labor. The agency recently named five companies to a denial order - essentially prohibiting their goods from entering the United States. Importers are responsible for ensuring that their suppliers are not using child or prison labor or that factories along the China / North Korea border are employing North Korean citizens to produce goods.
Assembly Bill 5 (or A.B. 5) in California is a piece of legislation that we're paying close attention to on behalf of our clients who use harbor truckers in and out of the state's ports. The legislation which passed the California Assembly and was signed by the Governor, is intended to protect workers in the gig economy - like ride share and food / product delivery drivers.

However, the law of unintended consequences means that this could ultimately affect whether or not trucking companies can manage the ebb and flow of their fleets through owner-operators. Some are reading this bill as meaning that the days of the owner-operator are numbered and that these drivers would need to be classified as employees of the company who is retaining them. If the latter becomes a reality, the cost for harbor trucking could increase.
An early reminder for next month that we have two federal holidays - Veteran's Day and Thanksgiving. For both, we're asking importers to keep mind that information will need to be in the hands of our teams earlier for filing AMS, ISF and other pre-departure notifications. Please speak with your Coppersmith representative for more details and the earlier cut-off dates to accommodate these holidays and office closures.
The complex issue facing carriers and shippers of low-sulfur fuel and the IMO 2020 mandate is laid out very eloquently in this recent article published in FreightWaves . The author's point - and the observation of an industry veteran - is that there won't be a direct line drawn from fuel cost increased by 'x' to BAF increased by 'x'. There are more complex calculations in play including capacity, backhauls and lanes. Essentially, he argues the market will set what the market will pay.
We've seen hundreds - literally hundreds - of bond increase letters sent to our importers by Customs over the past year or two because of the Section 232 duties on steel and aluminum and the Section 301 duties from China. When CBP says a bond must be increased, the new bond must be what importers forecast will be their total duty paid for the upcoming 12 months. We realize the strain these larger bonds carry - especially as sureties require financial instruments as collateral. We will continue to watch for duty increases and encourage importers to plan ahead in this ever-changing trade climate.