The compliance solution begins with the issuance of the purchase order. The importer is required to properly classify the goods, provide effective descriptions and product characteristics to ensure a proper entry. In addition, CBP expects care be undertaken to screen vendors prior to issuing POs. Establishing compliance at the time of PO issuance reduces risk far in advance of the goods being imported.

Classification
A product data base stores all necessary product classification information for required for data validation at the time of importation. This includes:

• SKU linked to Harmonized Schedule (HS) number
• Vendor/Manufacturer identification number (MID)
• Country of Origin and Export
• Special Trade Agreement indicators
• Store digital image of markings
• Other Government Agency (OGA) data
• Binding Rulings

Vendor Management
The supplier data base enables the managing of:

• Vendor/Manufacturer identification number (MID)
• C-TPAT evaluation status & risk assessment
• Participant (Y/N)
• Key Dates (Last, Next Evaluation and Certification)
• Certificate Number, Rating & Risk Assessment
• Denied Party Screening prior to engaging the party in a transaction
• Related Parties as it impacts duty calculations

Pre-Entry Process

All importers are required by law to provide the accurate entry information to either their Customs Broker or directly to Customs. The solution insures the highest level of data quality prior to submission to the Broker or CBP. Once the Commercial Invoice data is available from the vendor, the data is imported into Customs Link and validated against stored information and required data for the processing of the Entry (CBP 7501) in advance of the arrival of the goods at port. These can be scheduled such that the audits of the 7501 data are engaged prior to the tenth day deadline for entry summary filing and thus avoiding post-entry redress in the form of SILs, etc. Typical audits include:

• Is the Manufacturer ID on the Invoice the same as the PO or did the   supplier sub-contract to an unknown party?
• Are the products on the invoice classified in the product data base?
• Is the Country of Origin on the Invoice the same as the PO?

Compliant data can be submitted directly to CBP electronically using Oceanwide’s Automated Broker Interface (ABI) or to the Broker as a Proforma 7501 for processing.

Post-Entry & Broker Monitoring

If you are engaging the services of a Customs Broker, CBP expects controls and tools in place to oversee their activities and the entries that they are processing on your behalf. The Customs Management system supports receiving line item entry details (not summarized HTS data) back from the Customs Broker for audit and record keeping. Typical audits include:

• Does the value of the Commercial Invoice match the total entered value   (TEV) of the entry?
• Are there discrepancies with the MIDs, Country of Origin, Country of Export   & Tariff applied?
• From a receiving report, does the quantity received match the entry   quantity?
• What is the performance level of the Broker?

Payment Verification

The payment verification tool enables an audit of vendor payment data against the entry’s total entered value. A data feed from your Accounts Payable is used to match up against values submitted to customs. Discrepancies are quickly identified and underpayment of duties can be corrected with a Voluntary Tender Notice within the mandatory dates.

Audit & Recordkeeping

In addition to the audits discussed previously, the Customs Management supports the special recordkeeping and production requirements for certain entry records identified by CBP in the “(a)(1)(A) list”. As a general rule, any record is required to be made, kept and rendered for examination or inspection must be kept for 5 years from the date of entry. This is particular important if you are taking advantage of special trade programs like NAFTA. A record-keeping violation for a NAFTA entry may include penalties for both making false NAFTA claims and for record-keeping violations. The record-keeping penalty for negligence is $10,000 per entry.

Foreign Trade Zones

CBP has recognized that the special security measures that Foreign Trade Zones’ bring to the final leg of the international supply chain as a C-TPAT best practice. This is in addition to all the financial benefits of running an FTZ. Certain types of merchandise can be imported into a Zone without going through formal Customs entry procedures or paying import duties. Customs duties and excise taxes are due only at the time of transfer from the FTZ for U.S. consumption. The Customs Management system supports (FTZ) operations by automating the 214 zone cargo admissions and the weekly 3461 and 7501 entries. The system integrates with all common FTZ inventory management systems.

FTZ users also find that in meeting their FTZ reporting responsibilities to the U.S. government, they are eligible to take advantage of special Customs procedures such as direct delivery and weekly entry. These procedures expedite the movement of cargo, thereby supporting just-in-time inventory methodologies.

Oceanwide is the market leader in FTZ automation with CBP. We can help you reduce your processing costs and increase compliance for your FTZ operations by automating.

• Expedite cargo admissions into the zones with automation
• Eliminate inefficient paper-based submission of 214s
• Auto-calculate the Harbor Maintenance Fee (HMF), which can be extracted   for Quarterly Payment Report (CBP 349)
• Eliminates the need for additional Census reporting