07/26/2024
Catch Up on the GEODIS 6th Annual Trade Symposium: Recap of 10+ Sessions!
Check out this compilation of articles summarizing the panels and breakout sessions from the day.
The GEODIS 6th Annual Trade Symposium was hosted on June 5, 2024, in Lafayette Hill, Pennsylvania. Mike Honious President and Chief Executive Officer of GEODIS Americas kicked off the day with a multifaceted discussion on Transforming Logistics. He reviewed the GEODIS footprint around the world; our actions towards a responsible value chain; a brilliant overview of current economic trends and conditions; why the supply chain is a real time predictor of the economy; and then closed it out with how GEODIS is involved in empowering today’s youth and strengthening our communities. Overall, Mike’s keynote set the stage for a packed full day of learning and engagement, a day that many considered GEODIS’ best event yet!
Please enjoy a compilation of articles written by our very own GEODIANS summarizing the panels and breakout sessions from the day.
1) Sustainable Logistics: Taking Action, Measuring Impact and Driving Positive Change
– Ed Fitzgerald, Vice President, Trade Services, GEODIS
The 2024 GEODIS Trade Symposium kicked off the morning panel sessions with the topic of Sustainable Logistics: Taking Action, Measuring Impact and Driving Positive Change. The panel consisted of professionals from CBP, Penn State University, Climate Fresk, and GEODIS. With June 5th being World Environment Day, CBP presented their Green Trade Strategy Initiative. With increased climate change, CBP is implementing executive and legislative regulations to reduce carbon footprint by 50% with the use of EVs and innovation improvements in the supply chain. CBP wants to be a facilitator in removing barriers and increase sustainable trade both locally and globally. CBP is also developing initiatives in conjunction with fellow Government Partner Agencies (PGAs) in combating illegal logging, fishing, and mining of natural resources. To be successful, CBP needs assistance and partnership from private industry to ensure a measurable success.
From a higher education perspective, the science of substantial development has significantly increased with recent refinements and implementations with sustainability goals within the global supply chain. One aspect that higher education is taking a role in sustainability is challenging students to engage and learn by planning from the beginning to the end of the cycle of an item. To have a sustainable benefit, the background science and technology of an item needs to be known in correlation with the business aspect of product cost, development, sourcing, logistics, installation, and the pros and cons of each aspect. This perspective was supported by Climate Fresk in that action provides inspiration and learning which promotes engagement with people. Understanding and mapping the problems associated with climate change creates solutions and consumer trends for the benefit of sustainable products.
GEODIS as a global logistics provider is fully committed to sustainable logistics by reducing greenhouse gas emissions and environmental pollutants within the supply chain. GEODIS is partnering in expanding and developing transportation solutions for our customers which reduce carbon emissions and improve sustainable energy efficiencies. GEODIS is utilizing resources that can be recycled, reused, or resold from our terminals, office buildings and warehouses. Being a good citizen is one of GEODIS’ Golden Rules and empowers our employees to be creative and problem solvers. Serving people by delivering their goods all around the world takes innovative, sustainable, and ethical logistics and is a growth measured action plan for today and into the future.
2) Ethical Supply Chains: The Evolving Landscape of the Uyghur Forced Labor Prevention Act
– Eileen Family, Senior Manager, Trade Services, GEODIS
The panel, moderated by Jennifer Polidoro, Director of Trade Services, discusses the implementation and impact of the Uyghur Forced Labor Prevention Act (UFLPA) over the past two years. The panelists include Jeffrey Franz from CBP Forced Labor Division, Erin Williamson, Vice President of U.S. Customs Brokerage, and Alan Klestadt, Partner at GDLSK.
The panel discussed the enforcement of the UFLPA, providing insights into the review and detention statistics of shipments under this act. They highlighted the procedures for importers to challenge detention notices and clarified the roles within CBP, emphasizing the interactions between the CBP Port and the CEE in handling these cases. They also discussed the various mapping software providers available and the pros and cons of those resources.
UFLPA Implementation and Statistics:
- The Uyghur Forced Labor Prevention Act (UFLPA) has been in effect for two years now.
- From June 2022 to April 30, 2024, 8465 shipments were subject to UFLPA reviews and enforcement actions.
- Of these shipments, 46% were released, 40% detained, and 14% remain in pending status.
- The shipments, valued at $3.5 billion, span nine core sectors.
- Major countries of origin by entering value include Malaysia, Vietnam, Thailand, China, India, with Malaysia and Vietnam accounting for 73% of the total value.
Rebuttal Process for Detained Goods:
- Upon receiving a detention notice, importers can rebut the presumption that their goods were made with forced labor.
- Importers have thirty days to submit supporting documentation unless extensions are granted.
- There is uncertainty with the trade regarding the roles and responsibilities within CBP, specifically between the CBP Port and the Centers for Excellence & Expertise (CEE).
Roles and Interaction of CBP Divisions:
Jeffrey Franz explains his division’s role within CBP and the interaction between the CBP Port and the CEE.
Goods from Xinjiang Uyghur Autonomous Region (XUAR) are presumed to be made with forced labor and prohibited entry into the U.S.
Importers have two options if their goods are detained:
- Demonstrate that their goods did not involve Xinjiang.
- Prove that goods from Xinjiang were not made with forced labor, seeking an exception.
Mapping Software:
- Different software applications are useful as traceability due diligence, but they are not a guarantee. Release comes down to documentation, tracing, sourcing and how you can substantiate the tracing.
- Attorneys use both software and open-source resources, reviewing all supply chain steps, including Chinese websites and press releases.
- Systems are expensive and require significant internal resources for verification.
- Importers often lack the resources needed for thorough vetting.
- The real issue is no guarantee even though you screened your supply chain. CBP will not tell you where the connection is, you have to figure it out. Some software is not getting hits on goods that are detained.
- If a UFLPA detention is issued importers must decide whether to re-export or rebut the presumption within thirty days.
- Proactive measures include maintaining robust documentation and continuously reviewing and tracing supply chains.
3) Navigating Waves: Exploring Challenges and Triumphs in Ocean Freight
-Kevin Colligan, National Vice President of Sales, US, GEODIS
In a sea of compliance and trade topics, our ocean leadership rail and carrier representatives took the stage. The council discussed numerous topics including geopolitical, procurement strategy, and, carrier capacity. Here are current challenges and how to manage them:
Headwinds:
- Panama Canal Restrictions
- Easing and no longer seen as a long-term challenge
- EC Labor Negotiations
- Have begun and are “positive.”
- Canadian Rail Labor Negotiations-Ongoing.
- Waiting times at entry are starting are leading to port skipping.
- Early Peak Surge has led to capacity rate increases.
- Attracting talent remains difficult and drives higher labor rates, regardless of sometimes not getting positions filled.
Service Conditions:
- Prediction that service levels will move from 50% to 90% moving into 2025.
- Rates will stay elevated, however, will stabilize by EOY.
- Blank sailings will continue.
How Can Importers / Exporters Help Themselves?
- Honor their MQC’s, or demand will shift to other clients.
- Strong forecasting models.
- Open communication, no gamesmanship in negotiating (will hurt in long run.)
- Place value of cost when making decisions at current moment.
Other Topics / Questions:
- ESG-How to move it Forward?
- Carriers are making small improvements and have a plan of action.
- Customers need to notate the ESG requirements in RFQ’s and hold carrier accountable to support.
4) Insights Unveiled: A Discussion on Consumer Product Safety Regulation
– Annemarie DeVivo, Director, Customs Brokerage Product, US, GEODIS
On this panel we were joined by Arthur Laciak, eFiling Program Specialist with CPSC, Andrew Reitano, Regional Customs Manager on the Customs and International Trade Compliance Team at IKEA, a Beta Pilot test participant, and Geodis’s very own Erin Williamson, Vice President of US Customs Brokerage and Matt Wagner, Director of eSolutions.
The session began with Arthur Laciak providing an in-depth breakdown of what eFiling is and the importance of the role it plays. eFiling is a CPSC initiative under which importers of regulated consumer products will electronically file data elements from a certificate of compliance with U.S. Customs and Border Protection, via the Partner Government Agency Message set. Currently, CPSC only asks for certificate data once a product has been identified for exam and therefore, cannot use certificate data in its Risk Assessment Targeting in advance of a shipment arriving. CPSC expects eFiling to allow the agency to focus on high-risk shipments and for the industry to see improvements in risk assessment, enforcement, and trade facilitation. Risk scores will decrease for importers who electronically file valid data elements, resulting in fewer examinations of their cargo at the port.
We had an in-depth conversation about the Beta Pilot Test which was launched in the Fall of 2023 and allowed up to 50 participants. GEODIS, along with 3 of our importing customers, including IKEA are participating. This has been a collaborative effort between the importer, CPSC, the broker and all respective IT groups. The uplift of the Beta Pilot e-filing period has been used as feedback loop for all parties to hash out the intricacies of the process. Concerns such as not having the option to disclaim in the Product Registry along with general use products that will now be flagged for CPSC but do not require a claim were discussed.
Federal Register Notice 47922 which was issued on 6/4/2024 expanding the Beta Pilot test to 2000 participants and has been dubbed the voluntary period. This was driven by an increased interest from the community and gives more participants the opportunity to join, which we strongly encourage. It is also important to note that involvement does not have to be with your entire CPSC product library. You can begin with just one product or as many as you choose to start the process.
The consensus from our panel is eFiling is coming, being a part of the Beta Pilot has been both resourceful and beneficial to the buildout of a smooth transition to this new requirement. The message was clear get in early, plan and be prepared; get all your stakeholders together and aligned. Now is the time to get started.
GEODIS is happy to support and engage in conversation as you consider these upcoming changes and how your business will pivot to ensure compliance with eFiling.
5) Breakout Session – An Afternoon with eSolutions
-Steve Blau, VP Key Account Management / Business Development, GEODIS
Daniel Guaderrama, Bob “you are right” Broome, and Matt Wagner walked us through various reporting, visibility, and analytical tools to help our customers manage their business. The session was about learning and sharing capabilities. While spending time on US client needs, the message was clear these tools can be deployed globally.
Given GOEDIS has a single global operations platform, we can provide information to our clients across all markets we operate, with consistency. We leverage input data from various sources and formats, utilizing OCR, RPA, and machine learning technologies to help streamline information gathering, driving data quality.
A deeper dive of IRIS 3.0 was also covered during the session. What is new?? The tool delivers a better customer experience, access to performance indicators, IoT visibility, as well as delivering Emissions Reports, if GEODIS is the carrier, and Total Spend information.
Lastly the team shared a new Customs Brokerage Audit Tool developed to compare customer received data against the information we are transmitting to US Customs. This tool will help identify missing information and data entry discrepancies, prior to submission. This is a game changer!
If you missed the session and want further details, please contact your GEODIS representative.
6) Breakout Session- Foreign Trade Zones (FTZ)
– Cynthia Esposito, Director, Key Account Management – Americas, GEODIS
Our GEODIS Trade Seminar would not have been complete without some exciting information from our FTZ team of experts. Our customers asked and we delivered!
A high-level overview of FTZ’s (Foreign Trade Zones) was presented at our recent US Trade Seminar in Philadelphia by Shana Head, GEODIS Senior Director of FTZ Product and Devon Toughill of Philaport, the FTZ Grantee and Zone sponsor for the Philadelphia area.
- Where do we begin? GEODIS offers an ROI (Return on Investment) study at the onset of your exploration down the path of setting up your own FTZ or using an existing FTZ.
- What benefits might we see? Duty Inversion – Duty Avoidance – Duty Deferral and more
- How do we get started? Through the use of an FTZ expert such as GEODIS’ Shana Head and her team of experts, the client will be set up to succeed and navigate through the complex Zone Board and CBP approvals and designation process; software implementation; documented procedures; staff training an implementation.
As we learned at the seminar, “It takes a village” to both analyze, set up, and run a compliant and successful FTZ!
7) Breakout Session – Navigating Compliance Challenges and Fostering Collaboration: Insights from Uyghur Forced Labor Prevention Act Breakout Sessions
– Penny Ricas, Vice President, Key Account Management/Americas, GEODIS
In an era where human rights take center stage in global trade, the Uyghur Forced Labor Protection Act (UFLPA) presents a moral, financial, and compliance benchmark for companies. Our Trade Symposium Breakout sessions delved into the intricate web of ethical, legal, and operational adjustments necessary to align with UFLPA, spotlighting the dedication of participating companies to purging forced labor from their supply chains.
Everyone agreed that importers face a real challenge. It’s not just about avoiding the 65 companies on the CBP Entity list, but also ensuring that the wider network of Tier 2, 3, 4 suppliers don’t interact with those entities. The complex nature of supply chains makes it hard to spot and stop forced labor.
Attendees shared tools they utilize to conduct their due diligence, some of which are free to use such as Responsible Sourcing Tool (www.responsiblesourcingtool.org). Software tools that claim to easily identify forced labor in supply chains, such as Altana, Sayari, or Supply Shift are expensive, and their effectiveness is limited by the universe of data they collect.
We discussed the observation that many consumers claim they don’t want to purchase goods made by forced labor, yet regularly order goods through e-commerce sites, some of which have been accused of using forced labor from Xinjiang. CBP, DHS, and our entire government should put more effort into explaining to the American people the real data collected relative to use of forced labor around the globe, and promoting how UFLPA has improved the lives of people around the world, if indeed it has. A level playing field is necessary to support the investments U.S. importers are expected to make to ensure no imported goods are manufactured, in whole, or in part, by forced labor.
The big ask from our UFLPA break-out participants was transparency from CBP. What makes for a successful rebuttal? Why won’t CBP communicate what was found when detaining goods? Why not utilize the data provided in advance of shipment such as ISF and AMS filings to identify shipments that will be detained prior to loading? Why must an importer be subjected to detention after importing the same product, from the same supplier, multiple times and successfully rebutting the guilty presumption each time? All agreed that CTPAT Tier 3 Trusted Traders should enjoy some benefit when importing goods subject to UFLPA.
Most participants in the UFLPA break-out sessions agreed that successfully driving forced labor out of import supply chains requires a collaborative effort involving all entities within the supply chain, including Customs and Border Protection. To achieve this, it is essential to foster a culture of cooperation, ensuring transparency, and sharing the data collected to address and prevent human rights abuses globally.
8) Breakout Session - Transportation
-David Schlenger, Area Sales Director- East Region, GEODIS
The transportation breakout session was very well put together and had 4 separate panelists and components.
- Ocean Transportation:
- Ernesto Aramburu, Global Accounts Director, Hapag Lloyd
- Lars Jokumsen, Senior Director Ocean Product, GEODIS
- Agustin Lopez, SVP Ocean, GEODIS
- Air Transportation:
- Joe Kronenberger, SVP Air Freight, GEODIS
- Domestic Transportation:
- John Lower, Capacity Solutions, Vice President, GEODIS
- John Lower, Capacity Solutions, Vice President, GEODIS
On the Ocean side- Ernesto shared about the Red Sea / Middle East issues are creating incredible service disruptions in 2024- longer transit times, additional costs, and some capacity issues. He also talked about market capacity, with there being a 9 percent YOY increase in total cellular capacity and an idle fleet at its lowest levels. The nominal capacity matches a firm demand rebound. However, the Suez Canal blockade and to a lesser extent the Panama water level issues lead to vessel diversion and create a technical decrease in available capacity leading to tension on rates and capacity on most East West trades. Global Ocean Demand in 2024 has 10.6% growth against 2023 so far.
Ernesto shared the future landscape and the changing of the alliances. The 2M alliance of MSC and Maersk are ending and a new alliance with HL and Maersk called GEMINI will start in 2025. There will be four total alliances totaling 95 loops in total (proprietary slides were shared). Gemini will have a shuttle concept- with spokes and hubs- this is very new and will be interesting to see if this approach is as successful as they believe it will be for reliability and other reasons.
Lars talked about solutions out of Trans-Pacific due to the situation right now- 100% capacity, blank sailings, high rates.
We will have extra loaders 53’ to the West Coast starting in July, that we can end in LA or IPI all the way to the Midwest- fixed cost, fixed timeframe:
- LCL Solutions
- Geodis Lease Equipment
- Alternative solutions being worked out as well.
It was a very spirited conversation amongst the panel and the group.
Joe Kronenberger then spoke about air freight. He shared the following:
- Global Air Trade up 4% so far against 2023 YOY. Asia to Europe is up 10%
- Fashion is up 24% and Consumer Goods are up 12% so far YOY.(SLIDE 13 shared other markets too)
- Ecommerce air cargo is expected to be 13% of the total global A/F- was 6% in 2022 and 9% in 2023 so the growth is substantial.
- Up to 10,000 tons of Ecommerce cargo leaves China and HKG daily in 2024.
- Air Cargo Capacity has grown 10% in 2024.
Joe also shared some short- and long-term outlooks for the air market as well.
John Lower shared what is happening in ground transportation and the challenges that continue in that world. He shared the flat to negative nature of the market due to lack of demand, excess capacity, and flat rates continues.
John did share six best practices in the truckload space with the top two being:
- Be flexible on price duration as just going for the lowest price is not the best model
- The market is likely to remain fragmented for the rest of 2024.
Overall, the four parties who participated in the breakout session were the same Geodis and HL participants in the morning panel discussion. They did a great job of sharing more detailed information and the enthusiasm was evident in the room.
9) Breakout Session – USDA Organics
-Ben Vaughn, Director, Corporate Accounts, GEODIS
If you’ve ever wondered what is meant by the “Certified Organic” seal & increased price that goes along with it, it is through the USDA (United States Dept. of Agriculture) which has recently designed & introduced the National Organics Program (or “NOP”), which went into effect as of March 19, 2024.
Many companies in a variety of industries that claim to have organic products, ingredients or sourced from such, now have a task to demonstrate to USDA that their process & sourcing partners meet certain requirements for USDA to grant the above designation of “certified organic”.
The goal of this program is to accurately trace & confirm from “farm to store” the sources of ingredients & products used in the manufacturing & production of items considered to be or requested to be called organic. Things like use of natural processes, certain select pesticides, no GMO’s or genetically modified engineering, on site testing & inspections, etc. all help to define the organic designation.
The USDA only consists of about 80 persons overall, such that it would be nearly impossible for the agency alone to enforce the nearly 27,380 organic farms & businesses in the USA. As such, the government is working in a joint “public-private” cooperative venture. Together with the Natural Organic Standards Board, accredited 3rd party private certifiers, along with other certified organic businesses & organizations, the USDA hopes to spread the responsibility back to the individual companies, farms & businesses to take the necessary steps to ensure their supply chain is indeed accurate & can be deemed organic.
The USDA calls this renewed audit & review process “Strengthening Organic Enforcement” or SoE for short. Its purpose was to protect the integrity and further bolster confidence to the designation of Certified Organic. The plan is to (a) increase the number of applicants to better decrease the chance of fraudulent product or bad players, (b) strengthen supply chains & recordkeeping, (c) require use of electronic import certificates, and (d) give better authority & governance to accredited certifiers- at home & abroad.
The USDA also has partnerships with key governments in several trading partner countries- like Canada, Australia, Japan, Taiwan, Switzerland, Israel and several others that help to certify businesses in their respective countries which USDA would accept as legitimate.
The definition of what type of company should seek the new NOP electronic certification would be any company that produces or “handles” organic material. Handles is defined to include trade, exports, imports, or facilitates the trade or sale of organic material. Even some intermediary parties that would have been exempt previously (like traders, commodity brokers or importers) must now become certified to maintain the supply chain & remain designated “organic”. 3PL’s transportation companies, & customs brokers are, for the moment not required to seek certification, but as the program develops, it may be beneficial for certain client’s business to do so.
While the program is in place & enforceable currently, the USDA is aware that there are still many grey or unclear areas of the program & how & who needs to be certified & by when. In principle, they are open to receiving comments & questions from the business community to further hone the SoE, and application process. Right now the main exemptions from the SoE certification would be 1. An operation with annual sales < $5000, 2. a retail establishment that doesn’t process anything organic, or only does so at the point of final sale (i.e. no tampering or altering) 3. Some shipping & handling companies who strictly handle product under tamper-evident conditions, etc. not importers/exports and 4. Customs house brokers.
For USDA filing purposes, there is a temporary code (999) that is utilized while various companies & their supply chains get more up-to-speed regarding these new requirements. However, the plan is tentatively that by Sep 19, 2024, this temporary code will be replaced by a permanent filing code for USDA organics &
Whether from originating farm, or processor, to wholesaler, or final market seller, each step in the “farm to store” process needs to be looked into to ensure that your USDA application & clearances are not held up (or worse yet- fined $$) due to these new regulations.
A great deal of information regarding the SoE process, which companies are already certified on the USDA database, and the application forms, record keeping requirements, common Q&A, and communicating with the USDA can be found at the following link: https://www.ams.usda.gov/services/organic-certification/becoming-certified
10) Breakout Session – Free Trade Agreements and Duty Drawback
– Kim Willis, Key Account Manager, Business Development, GEODIS
In the complex landscape of international trade, navigating the intricacies of customs duties and trade agreements is paramount for businesses seeking to optimize their operations and maximize profitability. Two key mechanisms that can significantly impact a company’s bottom line are Duty Drawback and Free Trade Agreements (FTAs). Understanding these tools and how to effectively utilize them can provide businesses with a competitive edge in the global marketplace.
Duty Drawback: Refunding Duties for Exported Goods
Duty Drawback is a longstanding program established in 1789 that allows for the refund of up to 99% of duties paid on imported goods upon their exportation. The qualification for drawback varies depending on factors such as the product, its journey since entering the US, and the specific scenario. Industries such as automotive, pharmaceuticals, jewelry, and apparel frequently utilize drawback due to their high-value nature and the substantial duties imposed on their imports.
There are various types of drawbacks, including manufacturing, unused, and rejected drawback. Manufacturing drawback applies to materials that undergo a transformation process, while unused and rejected drawback pertain to goods that are either not utilized or are returned and subsequently exported.
Modernization efforts, such as electronic filing and streamlined procedures, have simplified the drawback process. Notice of intent must be filed electronically with Customs at least seven days prior to exportation, facilitating smoother transactions. Additionally, the Fast Track program expedites the refund process, with accelerated payment options available for eligible participants.
However, maintaining meticulous records is imperative, as non-compliance or insufficient documentation can result in delays or denials of drawback claims. Businesses must adhere to stringent record-keeping requirements and ensure compliance with customs regulations to maximize the benefits of the drawback program.
Free Trade Agreements: Facilitating International Trade
Free Trade Agreements (FTAs) are bilateral or multilateral agreements between countries aimed at reducing or eliminating barriers to trade. These agreements provide preferential treatment to goods originating from member countries, often through tariff reductions or exemptions.
The history of FTAs dates back to the aftermath of World War II when initiatives like the General Agreement on Tariffs and Trade (GATT) were established to promote global peace and economic prosperity. Over the years, FTAs have evolved, with the World Trade Organization (WTO) playing a key role in facilitating trade negotiations and resolving disputes.
FTAs can be classified as unilateral or reciprocal, depending on the nature of the agreement. Unilateral agreements involve one country granting preferential treatment to another, whereas reciprocal agreements involve mutual concessions between participating nations.
To determine eligibility for FTA benefits, businesses must classify goods according to the Harmonized Tariff Schedule (HTS) and adhere to specific rules of origin outlined in the agreement. This often involves verifying the regional value content or tariff shift of the product to ensure compliance with FTA requirements.
Customs scrutiny of FTA claims has intensified in recent years, with increased emphasis on compliance verification and documentation. Businesses must be proactive in their approach, conducting thorough validations and maintaining comprehensive records to support FTA claims.
Duty Drawback and Free Trade Agreements offer valuable opportunities for businesses engaged in international trade to reduce costs, increase competitiveness, and expand market access. By understanding the intricacies of these programs and implementing robust compliance measures, companies can unlock significant benefits and enhance their global trade capabilities. Effective utilization of duty drawback and FTAs can ultimately contribute to sustained growth and success in the ever-evolving landscape of international commerce.
11) Breakout Session – U.S. Antidumping & Countervailing Duties and Bonds
– Marina Tasiopoulos, Key Account Manager
Unfair foreign pricing and government subsidies distort the free flow of goods and adversely affect American business in the global marketplace. Enforcement and Compliance, within the International Trade Administration of the Department of Commerce, enforces laws and agreements to protect U.S. businesses from unfair competition within the United States, resulting from unfair pricing by foreign companies and unfair subsidies to foreign companies by their governments.
How do you know if your product is under an ADD/CVD Order?
- ITC Website: https://www.usitc.gov/investigations/import_injury
- Country
- Date
- Product group
- ITA website: https://legacy.trade.gov/enforcement/operations/scope/index.asp
- CBP website: https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#
- Query ACE
- Federal Register https://www.federalregister.gov/
- For preliminary determinations, need to search CBP admin messages.
In the past 10 years, cases have more than doubled. Currently, there are over 700 active orders. There is constant activity and monitoring of possible ADD/CVD products. There is significant financial impact to importers if your product falls within scope of these ADD/CVD cases. These cases take years to resolve. You must be prepared to post collateral for the full amount of bond and additional collateral year in and year out as the case stays open.
There has been more scrutiny from CBP. We have seen an increase in CF28s, audits, and DIS on possible ADD. You may file a 01-consumption entry, but Customs will reclassify it as a 03 ADD/CVD entry. CBP can also go back to past entries for review. It’s a challenge for our clients to monitor, however, importers need to manage their liability and do their due diligence.
Liquidation of entries is suspended for years which extends your liability, so you really don’t know your risk. After liquidation, Customs can come back and issue a bill and tell you to file a protest if you disagree.
Stacking aggregate liability if entries are not liquidated. The surety company will take the highest historical rate for that country to apply to open entries. The bond company will run reports to see what was liquidated after the protest period of 180 days to determine if the collateral can be reduced.
ADD/CVD dumping is determined by the Department of Commerce and injury is determined by ITC. You must have both dumping and injury to the US industry to assess ADD.
A US company or industry can file a petition, the Department of Commerce and ITC will see if it’s sufficient or not and then determine if an investigation is still needed. If there is no injury, then the case will end. If there is injury, then the investigation begins.
Final deposit rate can go up and down and take years to be finalized. It identifies manufacturers, there are two mandatory respondents. Suppliers can apply for review to get a lower rate otherwise other suppliers get an average rate.
The scope of the case is included in the petition and can be quite large and detailed. You can apply for scope ruling if you think your product doesn’t belong in scope.
12) Closing Session
Nick Zeitlyn, Director, District Sales-West/Midwest-Region, GEODIS
The 6th Annual GEODIS Customs Trade Event finished just the way it started… with Energy, Passion and being grateful for one another.
Lou Lambremont, our GEODIS Chief Commercial Marketing Officer for Americas, thanked our clients for attending the event, further went over our key intentions and goals for the conference and revisited what GEODIS wanted to achieve for our clients when they walked away from the event.
Goal 1: Networking
Many clients spoke up about the positive experience they had in being able to meet different people from quite different industries and share stories of success and challenges with each other. The Networking Goal of the event proved that no matter how different our backgrounds are, we can all find a common goal and experience with each other.
Goal 2: Education
Clients further discussed in the closing session some of the key educational moments they appreciated and took away from the event, which included key knowledge learnt in the morning presentations from our CEO Mike Honious discussing and educating the audience about the current Global and USA Economy and impacts it has on the clients Supply Chain short term and long term. Clients shared the appreciation on being able to learn more from speakers on the Panels that covered Environmental Sustainability, Forced Labor, Ocean Freight, Air Freight, Road, Consumer Safety and Regulation, and knowledge and information obtained in the GEODIS Breakout sessions covering Foreign Trade Zones, E Solutions, Transportation, Bonds, AD CVD, Free Trade Agreements, UFLPA and Drawback.
Goal 3: Fun
Fun was our 3rd major goal for the annual conference, and our clients very much agreed the event was both fun and productive for all.
A huge thank you must be given to:
- Lori Thompson and Alexa Antonioli, who worked tirelessly in putting this amazing event on and made sure everything ran smoothly and like clockwork.
- Brian Riley, who hosted the event, once again made sure that plenty of energy and fun was given into the event with a high level of education and knowledge being taken away from the event for our customers and prospects.
- All our speakers and guest panelists provided a wealth of information, covering a very broad range of hot topics that are trending both long term and short term in our industry.
- The Union League of Philadelphia, which was the venue of the 6th Annual GEODIS Customs Trade Event, the hospitality and warmth given to all attending was fantastic and very much appreciated.
The Day Finished off with a cocktail Reception where guests were entertained by an amazing Music / Singing performance from GEODIS Own, Phil Dunavan-AKA-Ben Vaughn, and an incredible Cameo performance from our one and only Paul Killea on the Harmonica.
It would be agreed by everyone, that a lot has happened in the last few years which has tested the human spirit Immensely. When we are lucky in having the opportunity to attend such events like the GEODIS Trade Symposium, it really does once again remind us how powerful human connection is, and that when we share and collaborate, we can all be unstoppable, and the sky is the limit!
See you all next year!
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