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Dispatch
July/August 2002 |
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Welcome to the first issue of Dispatch - an eNewsletter from Dutycalc Data Systems. Every other month we will be bringing you articles, news and tips on customs, drawback and trade related issues. We hope you find Dispatch of interest and help in your everyday responsibilities. Please email us your feedback and suggestions for future articles.
Carolyn Indreboe
President
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Recordkeeping - The Key To Drawback Compliance!
Recordkeeping - that painstaking process of keeping pounds (or bytes) of documents surrounding your importing, manufacturing and exporting activities - is a critical aspect of your drawback program. Four questions come to mind when thinking about the records one must obtain and retain for a drawback program to be compliant.
Why?
Why must records be obtained and retained? Simply to enable Customs to verify drawback claims. These records are used to follow the flow of goods from one stage to another. Records must link import to manufacture, and if applicable, to exportation.
What records need to be kept?
Typically, you should obtain and retain the following documents for drawback purposes, however you may want to verify that additional records are not needed.
- Import documentation such as the CF-7501 Entry Summary
- Certificate of delivery
- Purchase orders, invoices, packing lists
- Import bill of lading, import delivery records
- Bills of material, formulas
- Export bill of lading, invoices, packing lists
- Export invoices, packing lists
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New and Improved Web Site
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We've done it! Dutycalc has recently launched our redesigned Web site - www.dutycalc.com - featuring a new look and additional content for those in the import-export trade community.
We've added new features such as our "Drawback Central" section that includes resource links, regulation updates, articles, newsletters, tools such as a compliance checklist and the drawback discussion area. You will also find detailed information on our drawback software packages and services.
Of course, in addition to our redesigned Web site, we have launched this email newsletter - Dispatch - which will come to you on a bi-monthly basis. Please check out our new Web site and let us know what you think and what types of information and resources you'd like us to include.
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Who must keep these records?
An importer must keep all import-related documents. Should an importer transfer goods to another party then they must prepare a certificate of delivery (CD) that will need to be kept by the party obtaining the goods. The importer will need to keep records supporting the information provided on the CD.
A manufacturer is required to keep all manufacture or production records. Should a manufacturer transfer goods to another party for additional manufacturing or export, they must prepare a certificate of manufacture and delivery. Both parties should keep these records, although it is the principle manufacturer's responsibility to provide Customs with the records should they request them.
Any party other than the importer or manufacturer that transfers substituted commercially interchangeable goods, drawback products or manufactured goods has to provide a CD and must maintain those records. The recipient of the goods must retain the CD records.
As for the drawback claimant - who may be the importer, exporter, manufacturer, intermediate party or some combination of the four - they are required to keep records pertaining to the exportation for which the drawback claim is based. Otherwise the claimant must keep records applicable to their particular area of responsibility.
How long must records be kept?
Records must be kept for at least three years after a drawback claim has been paid by accelerated payment. However, this can be extended by Customs and your particular situation may require that records be retained indefinitely. Additionally, if Customs begins to verify a drawback claim just prior to the expiration date, records must be kept until Customs has finished its review.
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File Your Drawback Claims Through Dutycalc's ABI Service Bureau
Wouldn't it be great if you could process your duty drawback claims by way of ABI (Automated Broker Interface) without the expense of an ABI package? You would no longer have to wait for your drawback claims diskette to be processed. No more waiting to find out if corrections need to be made.
Filing your drawback claims through the Dutycalc ABI service bureau ensures that your claims are quickly and accurately recorded with Customs. Of course this results in immediate acceptance or rejection of your claim, faster claim processing and quicker issuance of your drawback refund.
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Helpful Hint
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ABI Error Message Dictionary: Ever have trouble translating the error messages from Customs on drawback claims you filed? Did you know that each and everyone of those error messages and its definition is listed on the Customs Web site?
Check out "ABI Error Message Dictionary" to get the complete listing of the various error messages and definitions that could possibly end up on one of your diskette or ABI filed drawback claims someday.
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Available to Dutycalc system users who do not already have the ABI capability to file their drawback claims, Dutycalc is now offering ABI filing services to non-Dutycalc system users who can provide a compatible diskette file. In order to get started, a filer will need to send a letter of request to Customs stating their desire to use Dutycalc as their ABI service bureau. To find out more about this service, contact Dutycalc at carolyn@dutycalc.com
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Quality Control, Customs Style
When you think the government is only looking out for itself, think again. The United States has more "watch dogs" out there looking after our well being than anyone could imagine. Under the Office of Information Technology Laboratories and Scientific Services, Customs operates eight laboratories throughout the U.S. that conduct a range of research and analysis on products imported into, and exported out of, the U.S. Below is a brief overview of the functions of each location:
CHIEF SCIENCE OFFICER: In Washington, D.C., Customs houses the Chief Science Officer (CSO) staff at the Office of Information Technology Laboratories & Sciences Services. Their main responsibility is the issuance of technical opinions to the office of Regulations and Rulings and to advise on World Customs Organization (WCO) issues. But this is only the start of Customs "watch dog" outfit. There are seven additional offices throughout the United States that perform various examinations and analyses on samples of products that are both imported into the U. S. and exported.
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Helpful Hint
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Drawback Info - Customs Site: If you have ever logged on to the U.S. Customs Web site you know how daunting it can be. Dutycalc has found a link within the Customs' Web site ("What Every Member of the Trade Community Should Know About: Drawback") that is an excellent tool for both those just starting out in the world of drawback and the seasoned drawback professional.
Customs details the legal obligations concerning duty drawback - including information to improve voluntary compliance with the various drawback rules and regulations imposed by Customs. Already involved with a drawback program? Don't forget to update yourself every now and then on Customs' requirements.
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RESEARCH/SPRINGFIELD: Springfield, Virginia houses the Customs research laboratory which provides scientific information to Headquarters and all the field laboratories. Information includes new methods for analyzing various commodities and the evaluation of new instrumentation which will be used by the field labs. The Springfield office is also responsible for providing the technical foundation for Intellectual Property Rights (IPR) enforcement - which involves copy rights, trademarks and patents on all varieties of product.
SAN FRANCISCO: The San Francisco Laboratory serves Northern California as well as several western states. This office provides technical advice and analytical services for a large number of imported and exported commodities to Customs officials as well as other government agencies. This lab and the other five labs located across the country, insure that items coming in and going out of the U. S. are above grade. In addition to the office located in downtown San Francisco, the lab has a mobile unit for on-site examinations. This particular lab specializes in the analyzing of apparel, footwear, metal products, food and beverages. The lab also analyzes certain chemicals and various controlled substances. Special emphasis is given to the analyzing of petroleum imported into the U. S.
NEW YORK: On the other side of the country is the New York Laboratory. Among other things, this lab provides scientific advice for the ruling program, technical information on drawback cases and training in the use of the Narcotic Test Kit for Customs officers and Agents. The lab also supplies an extensive textile testing program through the use of the Textile Field Kit making sure that what is imported into the U. S. is actually what it is purported and that it isn't an inferior product. They also give special emphasis to the testing of petroleum by way of their staff of National Petroleum Chemists who are responsible for the entire East Coast's imports and exports. New York also has a mobile operation working out of the JFK and Newark airports.
CHICAGO: The Chicago laboratory assists Customs offices with determining the best ways to collect revenue, in other words import duties. Chicago also assists with the enforcement of Customs rules and regulations. Interestingly, of the 23 employees at this lab, most are chemists or analysts who actively participate in national and international scientific organizations - working to improve the various methods of analyzing all types of commodities.
NEW ORLEANS: The New Orleans lab is one of two labs that date back to the early 1900's. As with the other labs, New Orleans analyzes both imported and exported merchandise to determine if the merchandise is described correctly on the proper documentation. The New Orleans lab also provides technical support in the areas of drawback, classification issues, regulatory audit functions and criminal and civil investigations. With only a staff of fifteen, New Orleans is responsible for developing a state-of-the-art instrument that can raise fingerprints off of a multitude of objects. Once a fingerprint is captured, the machine will be able to digitize it and match the prints electronically to other prints within the database. Customs will eventually be able to match raised prints with the FBI's own automated Fingerprint Identification System (AFIS) database.
LOS ANGELES: The Los Angeles laboratory provides analyses on textiles in the form of finished wearing apparel. The lab analyzes dyed fabrics as well as hand and machine loomed garments. The core focus of the Los Angeles lab is to provide technical assistance to Customs officers relating to forensic, commercial fraud and drawback enforcement.
SAVANNAH: Lastly, there is the Savannah, Georgia laboratory which has two locations, Savannah and San Juan, Puerto Rico. The Savannah lab began as a one room "sugar operation" in the early 1900's and has grown into a 20,000 square-foot location. What is special about this lab is its close proximity to the Customs training facility at the Federal Law Enforcement Training Center (FLETC) in Glynco, Georgia. The Savannah Laboratory provides specialized technical training to Customs import specialists, inspectors, and special agents and provides support to the agency's International Customs Training program.
FEDERAL LAW ENFORCEMENT TRAINING CENTER: As for FLETC, special training is provided to Customs officials in a variety of subjects, including narcotic and other controlled substance detection. FLETC also offers a Criminal Investigator Training Program (CITP) for Customs Inspectors which is their longest running course - taking upwards of 17 weeks to complete. Of the 75 or so courses offered by FLETC, many are offered off campus at the Savannah Lab in addition to numerous other locations, but a good many are held at this facility that also houses 23 full-time government agencies.
For more information about the Office of Information Technology Laboratories and Scientific Services please visit: http://www.customs.ustreas.gov/location/labs/labs.htm
For information about the Federal Law Enforcement Training Center (FLETC) please visit: http://www.customs.gov/news/news-0227-01.htm
FBI's Automated Fingerprint Identification System (AFIS) please visit: http://www.fbi.gov/hq/cjisd/iafis.htm
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Industry News & Events
Drawback Committee Meeting
AAEIAmerican Association of Exporters and Importers
New York, NY
September 10, 2002
Members and nonmembers are welcome.
Western Cargo Conference 2002
The Pacific Coast Council of Customs Brokers & Freight Forwarders Assns.
Annual meeting "High Stakes in a Risky Business"
Las Vegas, NV
Alexis Park Resort
October 24-27, 2002
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About Dutycalc
Dutycalc Data Systems is a Software and Consulting Company that designs, develops and implements management support systems for the Import, Export and Brokerage Communities. Our primary area of focus is Duty Drawback and the implementation of our fully automated Drawback System. Dutycalc is the leading drawback software companywith more than 200 systems implemented throughout the U.S.
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