Posts Tagged ‘FDA’


 

2017 Designation Maintenance Begins in our Professional Development Courses!

T if for Trade Compliance Education

A new year means a new start for most everything and this includes a reset to the maintenance requirements of your professional designations set forth by the credential’s governing body. We are well into the year now and our Professional Development Courses for fall 2017 are about to launch.

Whether you are a Canadian or U.S. Certified Customs Specialist (CCS), a Certified Trade Compliance Specialist (CTCS), a Certified Export Specialist (CES), a designate with the Law Society of British Columbia (LSBC) or accounting professional, taking any of Pacific Customs Brokers’ seminars and webinars will earn you maintenance points, credits and hours towards a variety professional designations.

Review and plan your maintenance for the second half of 2017 by clicking on the course’s name below:

(Fall registration opens at midnight on July 15, 2017)

  CSCB NEI LSBC
Webinar CCS CTCS CCS CES  
CDN Importing for Beginners Part 1
CDN Importing for Beginners Part 2
US Importing for Beginners Part 1 1
US Importing for Beginners Part 2 1
FDA Regulated Goods 2 2 1
CFIA Regulated Goods 2 2
NAFTA for Beginners Part 1 1 1
NAFTA for Beginners Part 2 1
 
Seminar
Shipping Perishables – NEW! 5 5 3 3
CDN Trade Compliance Part 1 5 5
CDN Trade Compliance Part 2 5 5 3
Exporting from Canada 5 5 3 3
US Trade Compliance Part 1 5 5 3
US Trade Compliance Part 2 5 5 3 3
HS Tariff Classification 5 6 4
Free Trade Agreements and Rules of Origin 5 5 5
Customs Valuation 5 3.5
CFIA 5 5
FDA 5 5 3
CTPAT 3 3 2 2

 

If you have never attended one of our Professional Development Courses before, the following information might help you decide on attending the next one.

Professional Development Courses – Webinars

Our webinars are designed to meet the demands of the global trade community. These live webinars are a convenient way for trade professionals to stay ahead of new regulations with international trade and gain additional knowledge in key areas. The benefits of attending an online course include:

  • Cost-effectiveness – More affordable than industry standards and some even offered complimentary
  • Global accessibility – Travel is removed from the equation for companies with multiple locations or branches
  • Convenience – Attend from the comfort of your desk
  • Concise training – In a fast-paced industry, efficiency becomes just as important as staying compliant
  • Industry recognized sessions – Earn points towards maintenance of your industry designations

Professional Development Courses – Seminars and Workshops

At these in-person sessions, you will learn the best practices on being compliant as an importer and/or exporter helping you expedite your commercial shipments rather than triggering costly delays. Our experts share their knowledge on international and cross-border shipping to keep you current with customs and participating government agency regulations.  The benefits of attending an in-person seminar or workshop include:

  • All day access – Get our experts to answer your questions one-on-one
  • Case studies and real-life examples – Examine other attendees’ trade compliance issues
  • Cost-effectiveness – More affordable than industry standards
  • Range of topics – Choose from a wide variety of seminar topics
  • Certificate of Completion – Receive a certificate for each course you attend
  • Handouts – Take home your own set of course material
  • Industry recognized sessions – Earn points towards maintenance of your industry designations
  • Networking – Connect with other like-minded professionals

For future reference, download your own 2017 Fall Trade Compliance Program today!

Trade Talk | This week in HS Tariff Changes

Trade Talk | This week in HS Tariff Changes

Trade – New 2017 Customs HS Tariff Codes in Effect NOW!

What we know for sure: HS Tariff changes

Getting your HS Tariff Code right is really important! The HS Tariff changes have been coming for quite a while and most are well known to customs brokers however let’s ensure that you, the vendors, are clear!

The current updates announced by the World Customs Organization (WCO) that came into effect as of January 22, 2017, are still being digested by most organizations. Our Trade Compliance Advisors have been on top of this for several months and are prepared to offer support where your company might need it.

If you are a client of ours, rest assured that we have already implemented the required changes and addressed all prior rulings that needed updating. If however, you are not a client of ours, we recommend you either contact your customs broker to ensure your tariff classifications and rulings are correct or contact our Trade Compliance Advisors. We are available 24/7 to provide this service on your company’s behalf.

What we are talking about:

The HS Tariff Changes had a large focus food products.

“The majority of the new changes to the HS have been broached by the FAO (Food and Agriculture Organization of the United Nations).

The HS 2017 amendments for fish and fishery products are to further enhance the coverage of species and product forms which need to be monitored for food security purposes and for better management of resources. The split by more detailed product forms for crustaceans, molluscs and other invertebrates is motivated by the importance of trade and consumption of these species in the various product forms.

The amendment for cuttlefishes and squids is to extend the coverage of the present codes, in order to have all those species grouped. At present, a significant share of cuttlefish and squid trade is recorded under residual codes for molluscs.”

With the final actions and rulings in regards to Forestry Products we are also talking about the amendments on this section of the WCO amendment announcement:

“The amendment for forestry products aims at one main area: enhancement of the coverage of wood species in order to get a better picture of trade patterns, including endangered species. In particular, separating the data on tropical wood trade will both serve to focus attention on the important issue of tropical wood use and clarify data on non-tropical hardwoods. The HS 2017 amendments also include the creation of new subheadings for the monitoring and control of certain products of bamboo and rattan, requested by the International Network for Bamboo and Rattan (INBAR).”

What we think:

We have been ensuring over recent months that our clients rulings are up to date with the changes and requirements laid out in the 2017 Customs Tariff. We are confident that our clients will, and have, found the transition to the 2017 Customs tariff seamless.

What we advise:

If you have a ruling on a classification we advise you to ensure that it is upheld under the 2017 customs tariff amendments, if you are not sure we highly recommend you contact a customs broker as soon as possible to avoid penalties, fines or worse, holdups of your company’s goods at border crossings.

Here is a great excerpt from our blog Your Broker Knows blog which covers tips on how to correctly classify your goods using the H.S. Tariff:

Key Reasons Why “Getting It Right” Is So Important: (The full article is here: http://bit.ly/2kagZzd)

Let us start with the area that everyone is aware:

  1.   Duty rates: The tariff classification has a direct correlation to the duty rate that you will be expected to pay (and no, it is not a matter of “finding the one that says FREE”).
  2.   NAFTA: This is very important as one of the first steps in determining if goods qualify under NAFTA is to find the tariff classification for the product and to then check under the NAFTA Specific Rules of Origin to determine how the goods might qualify. A common misconception is that products will “automatically” qualify if they are made in Canada, the U.S. or Mexico.
  3.   Anti-Dumping Duty (ADD): If a government decides that they need to protect a domestic industry, they can impose an anti-dumping duty on specific imports. This is also driven by the harmonised tariff classification. Pay close attention to this area as anti-dumping duty rates are always very high – usually double or sometimes triple digit percentages. For a full list of Canadian imports subject to dumping duties visit this link » Goods subject to anti-dumping or countervailing duties
  4.   Exporting to countries other than the U.S. where the shipment value exceeds $2,000.00? You or your freight forwarder will be required to complete a B13A export document (or electronic equivalent), and you will need the eight-digit harmonised system export code or the Canadian 10-digit import code for each product. Once again, export restrictions and permits governed by Foreign Affairs are driven by the tariff classification. The above topics are the primary reasons for determining the correct tariff classification. In addition, we should also include the controls through other governmental agencies, such as the Canadian Food Inspection Agency, Free Trade Agreements with other countries, and also the effects on Canada’s trade statistics.

Remember – If your company’s name is indicated as the importer on any customs documents, you (not your customs broker) are looked upon as the responsible party to ensure all declarations are correct. You may be able to avoid any future problems by getting it right the first time!

What we are reading:2017 Customs Tariff Amendments

The WCO has published the accepted amendments to the Harmonized System (HS) Nomenclature that went into force on 1 January 2017. It includes 233 sets of amendments, divided as follows: agricultural sector 85; chemical sector 45; wood sector 13; textile sector 15; base metal sector 6; machinery sector 25; transport sector 18; other sectors 26.

Link: http://bit.ly/2kI8prv

Along with the announcements and information shared on the WCO website, we are and have been, reading and disseminating the new Customs Tariff Documentation as you can see in this image – all 4 inches thick of it!

 

ACE Transition – Changes to FDA Entry Filing

Update

The U.S. Food and Drug Administration (FDA) has now completed its transition to the Automated Commercial Environment (ACE). As a result, all goods regulated by the FDA must be transmitted via ACE effective June 15, 2016 and will no longer be accepted in the previous Automated Commercial System (ACS). Additional information is now required when filing entries and corresponding entry summaries for FDA regulated goods.

What additional information will be mandatory?

  • Commodity details and intended use
  • Description of how the commodity is processed
  • Product state (i.e. fresh, frozen, shelf stable, etc.)
  • FDA product code
  • Country of production or source
  • Full and detailed invoice description
  • Full name and address of the:
    • Manufacturer
    • Shipper
    • Importer
    • Consignee
    • Consolidator
    • Farmer/grower (if applicable)
    • Processing plant (if applicable)
  • FDA registration number(s)
  • Port of entry
  • Quantity
  • Weights (actual, rather than estimated)
  • Packaging type
  • Product line value
  • Arrival date and time

Certain commodities may require additional information. Please contact Pacific Customs Brokers for additional details.

How will this affect my entry?

Pacific Customs Brokers may contact importers to obtain any mandatory information required for the entry filing with ACE and FDA.

As CBP and FDA implement this mandatory filing requirement entry filing delays are to be expected. It is imperative to note that missing information will result in additional processing delays.

Have questions or comments regarding the potential processing delays you may experience? Have tips for minimizing shipment delays? Share your thoughts with us. Leave them in the comments section below or email Ask Your Broker.

Biennial FDA Food Facility Re-registration Now Open

FoodAbout the Food Safety Modernization Act (FSMA) program:

The Food Safety Modernization Act (FSMA) improves the registration process by ensuring, among other things, that the FDA has accurate contact information for each facility. The new registration form also includes new categories of foods. These new categories will help FDA rapidly communicate with the right facilities in the event of an emergency.

Food producers and manufacturers have long been required to register with the Food and Drug Administration. Facilities can register online, via mail or fax. If your company is not domestic (not located within the U.S.) you will be required to assign a U.S. agent in your registration. See below for more information on assigning a U.S. agent.

Read more in our blog: Food Modernization Safety Act – Re-Registering your Facility with the FDA

The U.S. Food and Drug Administration (FDA) issued further information and guidance regarding registration requirements for domestic and foreign manufacturers, processors, packers or holders of food for human or animal consumption based on changes made by the FDA Food Safety Modernization Act (FSMA) to the Federal Food, Drug, and Cosmetic Act (FD&C Act).

Biennial registration renewal for food facilities began at 12:01 AM on October 1, 2014. The updated food facility registration system is accepting food facility registration renewals.

Who must register?

Under the Food Safety Modernization Act (FMSA), all domestic and foreign facilities that manufacture, pack or store food, food ingredients, pet foods or dietary supplements are required to renew their registration with the FDA before the end of 2014 and to re-register every two years thereafter. This represents a change from the previous registration requirement for food facilities. The re-registration form contains new food categories, and requires more detailed and updated contact information.

 Read more in our blog: U.S. Food Safety Modernization Act – Does It Affect Me?

How to re-register a domestic company?

To submit a registration renewal to FDA, a food facility is required to submit required registration information to FDA, including the additional registration information.

If you are affected by the new regulations, you may re-register your food facility online.

How to re-register if not a domestic company?

Pacific Customs Brokers offers the following services:

  • Act as your U.S. Agent
  • Assist with FSMA re-registration
  • Answer your queries regarding FDA requirements

Note: Pacific Customs Brokers does not have to be your U.S. customs broker in order to assist your company with FSMA re-registration.

 

Contact Pacific Customs Brokers for assistance with food facility registrations or the FSMA. To stay current on this topic, you may also want to subscribe to Pacific Customs Brokers weekly trade newsletter.

 

Do you have questions on the FDA food facility re-registration? Share them in our comments section below.

FDA Releases Updates to FSMA Proposals

Food Safety StampThe Food and Drug Administration (FDA) proposed a number of new rules during 2013 which have been in various stages of “public comment” for some time. The FDA has recently announced updated proposals to four of the seven rules, based on feedback received from the public.

Four Food Safety Modernization Act Rule Revisions

These four updated proposed rules include:

  1. Produce Safety – More flexible criteria for determining the safety of agricultural water for certain uses and a tiered approach to water testing. A commitment to conduct extensive research on the safe use of raw manure in growing areas and complete a risk assessment.
  2. Preventive Controls for Human Food – Requirements that human food facilities, when appropriate, test products and the food facility’s environment, as well as implement certain supplier controls.
  3. Preventive Controls for Animal Food – Requirements that animal food facilities, when appropriate, test products and the food facility’s environment, as well as implement certain supplier controls.
  4. Foreign Supplier Verification Program – A more comprehensive analysis of potential risks associated with foods and foreign suppliers, and more flexibility for importers in determining appropriate supplier verification measures based on their evaluation of those risk

Modifications to Originally Proposed Rules

Some of the modifications to the originally proposed rules include:

  • Revisions to the water quality testing provisions to account for natural variations in water sources and to adjust its approach to manure and compost used in crop production pending further research.
  • Revised definition of which farms would be subject to the produce safety rule, eliminating farms with $25,000 or less in produce sales from being subject to this rule.
  • Spent grains, which are byproducts of alcohol brewing or distilling, commonly used as animal feed,would not be subject to both the animal food rule if the facility already complies with the human food rule.
  • Extended flexibility to determine appropriate supplier verification measures based on risk and previous experience with suppliers.

Commenting on Proposed Regulations

The FDA states that they will accept comments on the proposed revisions for 75 days, and will continue to review previously submitted comments on parts of the rules that will remain the same in their final iterations.  Final rules are now scheduled to be issued in 2014, and will become final within 90 days of issuance.

We should bear in mind that there are still other proposed rules within the FMSA that are in different stages of completion. These are just four of those issues that we believe are of primary importance to importers and exporters who need to ensure all parties within your supply chain are complying with these rules that are now expected to be in place during 2015.

As food and beverage producers adapt to an array of stringent food safety requirements in the coming year, Pacific Customs Brokers is here to help. We can assist you in understanding these regulations and how they may affect your business, all while cutting through the red tape of importing to the United States.

 

Do you have questions about these updates to FSMA proposals? Use the comments section below to offer your thoughts or email Ask Your Broker.

 

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