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How Important is it to Screen Your Suppliers? Ask ZTE.

A smartphone being used as a GPS on a car dashboard.

I recently took an Uber in New York City and noticed that the drivers tend to have their smartphones mounted on their dash to allow them to use city maps. What humored me was seeing that my driver didn’t have the most common iPhone or Samsung Galaxy device, instead he had a Zhongxing Telecommunications Equipment (ZTE) smartphone. I chuckled at the irony and thought, “well that’s the last ZTE phone he’ll ever own,” at least for the next seven years.

ZTE is the fourth-largest smartphone vendor in the U.S. and sells to major mobile carriers such as AT&T, T-Mobile, and Sprint [1]. As the second largest telecommunication provider in China, they are a manufacturer and integrator of networking apparatuses and handheld devices [2]. The most common ZTE models include the Tempo X, Prestige 2, and Majesty Pro.

Not All Press is Good Press

Throughout the last couple of years, ZTE has made U.S. trade compliance news multiple times, but on April 20, 2018 they made headlines in bold font. ZTE had the unfortunate honor of achieving the highest export monetary penalty issued by the Bureau of Industry and Security (BIS) at $1.9 billion. This penalty was originally issued in March 2017 but ZTE was granted monetary deferrals and delays of suspensions, therefore April 20, 2018 was the official activation date.

Along with this hefty financial penalty, ZTE is no longer able to receive products from the United States. The impact of this on ZTE has been so substantial to its bottom line that they have had to halt operations [3].

So how does this apply to the Uber driver with his ZTE smartphone? Now that ZTE is frozen from receiving exports from the U.S.—or on behalf of the U.S.—his friendly retailer can no longer purchase from ZTE.

Why? Multiple exports occur in order to buy handheld devices from ZTE.

Export one: The retailer needs to request making a purchase, likely by email.

Export two: Then they will need to send a purchase order.

Export three: Finally, they must pay for the devices to be shipped from China, or a third party.

In between these transactions, there may have been additional communication by email or phone, which are all exports and are therefore banned.

While the Federal Communications Commission (FCC) grapples with the conflict between consumer interest and regulatory compliance, ZTE device owners have to wonder, will they be able to receive operating system downloads [4]?

Why ZTE Was Issued This Penalty

ZTE received components and equipment from the U.S. that were then transshipped to Iran and North Korea. In some cases, these products were not transformed but were shipped as is, and in other cases, they were put into telecommunications equipment to modernize the capabilities of the respective country—i.e. Iran and North Korea. This was a direct violation of U.S. sanctions.

Export compliance consultants and practitioners everywhere have been screaming, “screen your suppliers,” and now ZTE has given us a tangible example of why it is so crucial to practice export compliance within the supply chain.

The Nature of Their Deceit

It started back around January 2010, when ZTE began bidding on two Iranian projects where they would install cellular and landline network infrastructure. Through 2016 those contracts resulted in the illegal transfer of approximately $32,000,000 of U.S.-origin items, which were installed and used in Iran. During this time, it was also discovered that ZTE made 283 shipments of U.S. products to North Korea, these shipments included routers, microprocessors, servers, etc.

ZTE’s senior management knew they were in the wrong. In the summer of 2012, they required each employee involved with sales to Iran to sign nondisclosure agreements in which the employees agreed to keep all information related to the company’s exports to Iran confidential [5]. This resulted in employees providing false end user details to U.S. exporters and manufacturers.

During the two settlements in 2016 and 2017, ZTE had assured that all employees would be trained on compliance with U.S. export regulations and process updates. They also advised that internal audits would be conducted, and most importantly, top executives directly involved in the sales to North Korean and Iran would be disciplined for their actions, including the possibility of dismissal and at minimum a loss of bonuses. Earlier this year, the Department of Commerce (DOC) followed up with ZTE on the 2016 settlement requirements (internal audits, discipline of senior managers, implementation of compliance processes in line with U.S. regulations), as ZTE was allowed to continue business with the United States—a case of the U.S. attempting to maintain a flow of commerce—with the assumption that they would fulfill these requirements. However, ZTE failed to comply and falsely stated that all requirements were met, which has led to their current situation [6].

The Impact on U.S. Exporters

Not only is the ZTE ruling a hindrance to those who sell to or purchase from ZTE, but it is also impacting legal, legitimate, and profitable business for U.S. suppliers. As a manufacturer, ZTE has been involved in the modernization of telecommunication networks in many countries. For the U.S. exporter, sometimes ZTE is their customer and at other times, they are simply the middle man—the integrator, installer or operator. The ban on exports not only forbids new sales to ZTE, it also halts any pre-existing contracts, if ZTE is listed or known as an intermediary party on those contracts, mainly to entities that are based around Asia Pacific and the Middle East.

U.S. corporations must consider the impact this will have on ongoing services and maintenance requirements of existing telecommunications systems involving ZTE. If ZTE is the operator and has sold maintenance services to end users, ZTE is no longer able to purchase parts from the U.S.—directly or indirectly—or receive technical information to conduct that service or maintenance.

The Moral of the Story

We all understand that diverting goods to Iran or North Korea is against U.S. sanctions, but why was there such a hefty penalty? Well, ZTE had its own Hollywood-style-drama of lies and deceit which included making false statements to U.S. and Chinese attorneys and investigators, falsifying customs documentation, and mixing U.S. product with Chinese origin product in attempt to hide it.

What all of this tells us is just how important it is to ensure your vendors are compliant with U.S. export and import regulations. It also tells us to avoid single-sourcing providers, integrators, installers, etc. to help avoid major impacts to your business, if a situation like this arises.

A Chance for a Third Strike

After the April 20, 2018 penalty activation, ZTE did file documentation with the DOC again, stating they will train and audit their staff and processes, as well as discipline their senior team. The DOC has stated they are willing to see evidence.

Will ZTE have an opportunity for a third strike? With U.S. component—or chip—manufacturers suffering from a significant drop in export sales due to the inability to ship to ZTE, and the realization of possibly losing 75,000 jobs in Beijing China, we can expect ZTE to stay a topic of trade news for months to come. Also, due to the ongoing fear of a trade war with China, the BIS’s decision may be overturned by the Executive Branch.

President Trump has offered his assistance in resolving the issues between ZTE and the U.S. government [7]. How that help will be facilitated is unclear but does assure that ZTE will be a household name throughout 2018, with constant media attention. It is imperative for U.S. importers and exporter to stay current on trade news to assure compliance, as well as understand how these issues may impact their organization and bottom line.

MGTA’s import and export audit services can help you to uncover gaps in your compliance procedures. Contact Mohawk Global Trade Advisors to discuss how we can help you develop or improve your current import and export compliance programs.


Footnotes:

[1] “Company Overview,” ZTE USA. Retrieved on May 17, 2018 from <https://www.zteusa.com/about-us/>.

[2] Meyer, David, “One of the World’s Biggest Phone Firms Is Stopping Operations Because of a Ban on Buying U.S. Parts,” Fortune, May 10, 2018. Retrieved on May 17, 2018 from <http://fortune.com/2018/05/10/zte-components-china-technology-denial-order/>.

[3] Jiang, Sijia, “China’s ZTE Says Main Business Operations Cease Due to U.S. Ban,” Reuters, May 9, 2018. Retrieved on May 17, 2018 from <https://www.reuters.com/article/us-zte-ban/chinas-zte-says-main-business-operations-cease-due-to-u-s-ban-idUSKBN1IA1XF>.

[4] Dave, Paresh, & Shepardson, David, “China’s ZTE May Lose Android License as U.S. Market Woes Build,” Reuters, April 17, 2018. Retrieved on May 17, 2018 from <https://www.reuters.com/article/us-usa-fcc-china/chinas-zte-may-lose-android-license-as-u-s-market-woes-build-idUSKBN1HO2BD>.

[5] “ZTE Corporation Agrees to Plead Guilty and Pay over $430.4 Million for Violating U.S. Sanctions by Sending U.S.-Origin Items to Iran,” The United States Department of Justice, March 7, 2017. Retrieved on May 17, 2018 from <https://www.justice.gov/opa/pr/zte-corporation-agrees-plead-guilty-and-pay-over-4304-million-violating-us-sanctions-sending>.

[6] “Secretary Ross Announces Activation of ZTE Denial Order in Response to Repeated False Statements to the U.S. Government,” Department of Commerce, April 16, 2018. Retrieved on May 17, 2018 from <https://www.commerce.gov/news/press-releases/2018/04/secretary-ross-announces-activation-zte-denial-order-response-repeated>.

[7] Trump, Donald J., Twitter, May 13, 2018. Retrieved on May 17, 2018 from <https://twitter.com/realDonaldTrump/status/995680316458262533>.


By Kristen Morneau, Senior Advisor

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©2018 Mohawk Global Trade Advisors

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Updates from the Recent Steel and Aluminum Proclamations

Steelandaluminumtariffupdate

President Trump has issued two proclamations, on April 30, that extend temporary exemptions from the Section 232 duty on steel and aluminum products, along with other adjustments.

These are some of the main takeaways.

  • President Trump has extended temporary exemptions for Argentina, Australia, Brazil, Canada, Mexico, and the member countries of the EU.
  • The proclamation on steel also sets a quota, which restricts the quantity of steel articles imported into the United States from South Korea.
  • No drawback will be allowed for steel and aluminum section 232 duties.

If you have any questions about how these proclamations may impact your business, contact Mohawk Global Trade Advisors.

By Danielle Leonard

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Importer Security Filing Importer Definition Expanded

Importer Security Filing importer definition expanded

Customs and Border Protection (CBP) has issued a final rule, effective May 14, that will expand the definition of an Importer Security Filing (ISF) importer—the party responsible for filing an ISF for certain types of shipments. The changes will add parties that have a commercial interest in the cargo and the best access to the required information.

Before the Rule

Currently, the regulation designates a ISF Importer even if that party has no commercial interest in the shipment and limited access to the ISF data. In some cases, the party responsible may not even be involved in the importation when the ISF must be filed. Therefore, it is unclear as to which party has the responsibility for filing the ISF. It is also raises confidentiality concerns because there are times when the private party, that has the data, gives it to the ISF importer who then sends it to CBP, causing the information to be passed through many hands.

After the Rule

The new definition will expand the definition of ISF importer for foreign cargo remaining on board (FROB) cargo, by adding non-vessel operating common carrier (NVOCC) instead of just the vessel operating common carrier (VOCC), depending on which of these is the party causing the goods to arrive. The rule will also add to the definition of ISF importer for Immediate Exportation (IE) and Transportation and Exportation (T&E) shipments by including the goods’ owner, purchaser, consignee, or agent such as a licensed Customs broker, as well as for goods delivered to an Foreign Trade Zone (FTZ). This will ensure that the responsible party will most likely have direct knowledge of the ISF data.

By expanding the definition this rule will simplify the transmission of ISF information to CBP, eliminate confusion regarding the responsible party, and significantly reduce confidentiality concerns. If you have questions about this final rule or are interested in building an Import Compliance Program contact Mohawk Global Trade Advisors.

By Danielle Leonard

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Highlights from Trade Fest 2018

A collage of images from Trade Fest 2018

Mohawk Global Trade Advisors (MGTA) had a great turn out at this year’s Trade Fest in Syracuse, NY. We’d like to sincerely thank all of the attendees, speakers, and sponsors for making the event a success.

The day was filled with insightful seminars discussing various topics such as, economic trends, critical issues and what’s ahead, import and export compliance in your supply chain, and more.

This event was live tweeted by Mohawk’s marketing team; here’s a small sample.

 

   
 


 

   
 


 

   
 


 


 

 
A special thank you to our sponsors Mohawk Global Logistics, High Tech Rochester, Philips Lytle LLP, Avalon Risk Management, The Bank of America, Roanoke Insurance Group, Duble & O’Hearn Insurance, and Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP. We wouldn’t have been able to do this without you.

Trade Fest recap 2018-our sponsors

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Forced Labor and Chocolate: Do You Know Your Suppliers?

Hands holding a pile of roasted cocoa beans

On February 26, class action lawsuits were filed against Hershey and Mars in Massachusetts for failing to disclose that the cocoa in their chocolate was the product of child or forced labor. According to Hagens Berman, these two companies regularly import cocoa beans from suppliers in the Ivory Coast who are known to use the worst forms of child labor, including dangerous child labor and the slave labor of trafficked children. How well do you know the labor that your suppliers use?

Establishing Reasonable Care

Class action lawsuits are just one of consequences importers can face if they underestimate the importance of Reasonable Care. In September of 2017, U.S. Customs and Border Protection (CBP) updated their Informed Compliance Publication on Reasonable Care to include a forced labor section in an effort to create further awareness. Ultimately, it is up to the importer to practice due diligence and know what’s going on in their supply chain.

To assist, CBP has a Forced Labor Enforcement fact sheet aimed to inform and therefore fight the risks of forced labor within companies’ operations and global supply chains. This Responsible Sourcing Tool, can also help supply chain owners visualize each country’s risk of child labor and forced labor.

Have you taken measures under Reasonable Care to ensure your imported goods are not produced wholly or in part with forced or child labor? Here are some questions that importers should ask themselves to prevent the use of forced labor in their supply chain.

  1. Have you established reliable procedures to ensure you are not importing goods in violation of 19 U.S.C. § 1307 and 19 C.F.R. §§ 12.42-12.44?
  2. Do you know how your goods are made, from raw materials to finished goods, by whom, where, and under what labor conditions?
  3. Have you reviewed CBP’s Forced Labor webpage, which includes a list of active withhold release orders and findings, as well as forced labor fact sheets?
  4. Have you established a reliable procedure of conducting periodic internal audits to check for forced labor in your supply chain?
  5. Have you established a reliable procedure of having a third-party auditor familiar with evaluating forced labor risks conduct periodic, unannounced audits of your supply chain for forced labor?
  6. Do you vet new suppliers for forced labor risks through questionnaires or some other means?
  7. Do your contracts with suppliers include terms that prohibit the use of forced labor, a time frame by which to take corrective action if forced labor is identified, and the consequences if corrective action is not taken, such as the termination of the contractual relationship?
  8. Have you developed a reliable program or procedure to maintain and produce any required customs entry documentation and supporting information?

To counteract items of child and forced labor from entering into your sales channel and global supply chains, you should have a documented comprehensive and transparent social compliance system in place. If you need guidance on starting or enhancing a social compliance system for your company, contact Mohawk Global Trade Advisors.

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HTS Codes Affected by New Steel and Aluminum Tariffs

Steel 580

Yesterday—March 8, 2018—President Trump signed a tariff proclamation that placed a 25% tariff on steel imports and a 10% tariff on aluminum imports from all countries except Canada and Mexico.

HTS Codes Affected

Steel Articles

  • 7206.10 through 7216.50
  • 7216.99 through 7301.10
  • 7302.10
  • 7302.40 through 7302.90
  • 7304.10 through 7306.90

Aluminum Articles

  • 7601—unwrought aluminum
  • 7604—aluminum bars, rods, and profiles
  • 7605—aluminum wire
  • 7606 and 7607—aluminum plate, sheet, strip, and foil (flat rolled products)
  • 7608 and 7609—aluminum tubes and pipes and tube and pipe fitting
  • 7616.99.51.60 and 7616.99.51.70—aluminum castings and forgings

Presidential Proclamation—Steel

Presidential Proclamation—Aluminum

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No Need for Green Form for United States-Israel Exports

Shaded green, a man writes on paper.

If you export goods that qualify under the U.S.-Israel Free Trade Agreement (ILFTA), you’ll be glad to know that the hard copy certificate of origin—also known as the Green Form or Form A—has been replaced with a simple declaration, effective January 10, 2018. U.S. exporters can now prepare the declaration on either their invoice, delivery note, or on their letterhead.

We recommend that you thoroughly review the rules of origin to ensure that your goods qualify, prior to completing and signing the country of origin declaration.

Be aware that the Israeli Customs Authorities may ask you to complete a Verification Declaration to support your claim and you must retain proof of your ILFTA qualification for five years. Export.gov recommends that you keep, at least, the following information:

  • A description of the article, quantity, numbers and marks of packages, invoice numbers, and bills of lading.
  • A description of the operations performed during the production of the article in the U.S. and identification of the direct costs of processing operations.
  • A description of any material used in production of the article, which are wholly grown, produced, or manufactured in the U.S., and a statement of the cost or value of these materials.
  • A description of the operations performed on and a statement as to the origin and cost or value of any foreign (non-U.S.) materials used in the article, which are claimed to have been sufficiently processed in the U.S. making them materials produced in the U.S.
  • A description of the origin and cost or value of any foreign (non-U.S.) materials used in the article, which have not been substantially transformed in the U.S.

Below is a sample declaration that you may include on your commercial invoice or have as a separate declaration on your letterhead.

U.S. Israel Origin Invoice Declaration

I, the undersigned, hereby declare that unless otherwise indicated, the goods covered by this document fully comply with the rules of origin and the other provisions of the Agreement on the Establishment of a Free Trade Area between the Government of Israel and the Government of the United States of America.

Check one that applies:

___ The Exporter
(whether the exporter is the producer or not)

___ The Producer
(is not the exporter)

Tax Identification:

Name:

Title:

Email:

Signature:

By Jim Trubits, Vice President

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Why Do My Goods Need to be Marked with the Country of Origin?

Clean paint brushes labeled as made in Germany.

Receiving a marking notice from Customs and Border Protection (CBP) could cost your company a lot of money. It might result in additional expenses in trucking fees and third-party warehouse service fees to unload your cargo. Not to mention, the added cost to correct the unmarked, or inaccurately marked, merchandise. In addition, you would not be able to sell your goods until they were properly marked, which would cause delays or lost sales. Eventually, if you unmark or inaccurately mark future orders, CBP may step up exams, issue penalties, or assess a 10% marking duty on your products.

Why do my goods need to be marked?

Under Reasonable Care, CBP requires the importer to establish reliable procedures to verify that their merchandise is properly marked with the correct country of origin—upon entry—and that it matches CBP’s documents.

When do my marking obligations start?

Your responsibility begins prior to importing, as the goods must be correctly marked when they are imported into the United Sates. Therefore, it is important to give your vendors clear guidance on how to mark and label your goods, in order to meet the country of origin marking requirements.

What options do I have, if CBP discovers my goods are not marked?

You have three options.

  • Re-export the goods.
  • Destroy them.
  • Mark the goods properly using one of the CBP’s acceptable methods.

Any unmarked goods released into the commerce of the U.S. may be subjected to marking duties and penalties by CBP.

What steps should I take under Reasonable Care to prevent marking issues?

  • Work with your marketing group when they are developing new products and packaging, in addition to making changes to existing packaging.
  • Notify your vendors, in writing, of the country of origin marking requirements for the product, packaging, and Customs documentation.
  • Establish procedures to verify the correct country of origin is on the entry and Customs documents. Also, confirm the goods are properly marked when they are received at the warehouse.
  • If any errors are discovered, take immediate steps to document and correct them.

By Jim Trubits, Vice President

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Increased Civil Penalties for Export Violations

A judges gavel hits a pile of money

The Department of Commerce and Department of State have increased the civil monetary penalties for export violations to account for inflation, effective January 15. It is important to recognize that these new amounts are retroactive and can be charged against each violation, regardless of when the violation occurred.

Here is a summary of the penalty increases:

  • The maximum amount for an EAR civil violation is now $295,141 or two times the value of the transaction (50 U.S.C. 1705(b)).
  • Penalties for late AES filings are now $1,360 per day; with the maximum per violation increasing to $13,605. All other AES violations are now $13,605 (13 U.S.C. 304 & 13 U.S.C. 305(b)).
  • The penalty for Directorate of Defense Trade Controls (DDTC) civil penalties has increased to $1,134,602 per violation (22 U.S.C. 2778 (e)).

The adjusted penalty amounts serve as a reminder to keep your export compliance program and training up to date. Make sure you monitor your export transactions and processes, and if you do discover an export violation, consider making a voluntary disclosure.

Contact us and ask how to we can help you build a custom export compliance program.

By Danielle Leonard

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9 Most Common Medical Device Entry Screening Errors

Medical devices hung on a wall in a doctors office.

While importers of medical devices may not see the benefit of each entry line being scored through the U.S. Food and Drug Administration’s (FDA) Predictive Risk-based Evaluation for Dynamic Import Compliance Targeting (PREDICT) system, this process has the potential to help speed up entry screening of their medical devices.

What is PREDICT?

PREDICT—the FDA’s electronic screening tool for import operations—is designed to assist entry reviewers in targeting higher-risk shipments for examination. It works behind the scenes to screen all lines of imported product electronically submitted to the FDA through the U.S. Customs Automated Commercial Environment (ACE) via the Automated Broker Interface (ABI) and then assigns a score to each line. A high score means a higher risk and a low score means a low risk. If your PREDICT score is lower, the product has the potential to clear faster.

Keep Your PREDICT Score Low

Importers should ensure they provide accurate and complete data, whether they file their own entries or have a Customs Broker file for them. If there is inaccurate or missing data, such as failing to provide a device listing number or entering inaccurate product codes, your PREDICT score goes up and is flagged as high-risk. This could result in delays for present and future shipments.

How to Avoid Common Errors

The FDA has provided a list of the most common errors for medical devices in fiscal year 2017. This should help importers and entry filers identify the types of criteria they might be missing or providing incorrectly.

When in doubt, importers should use reasonable care when providing entry data. Ensuring you supply the most accurate information will help keep your PREDICT score down and result in a low-risk rating, thus expedite the screening process.

Below are the FDA’s most common entry errors for medical devices.

Most Common Entry Errors for Medical Devices in 2017

LST not transmitted
No listing number (LST) was transmitted for the entry. Verify that a listing number is required and provide one as applicable. There is no public website to search listing numbers because they are proprietary. Contact the listing entity to retrieve the number.

Could not find LST number
The listing number transmitted could not be found in FDA’s database. Verify that the listing number provided is accurate and in the correct format.

Rgstrn not trnsmttd (DEV/DFE)
No registration number was transmitted for the foreign manufacturer (DEV) or foreign device exporter (DFE). Verify that a DEV, DDM or DFE is required and provide one as applicable.

Mnfctr has Country code = US
The listing number transmitted indicated that the manufacturer was a U.S. firm, but the manufacturer provided on the line is a foreign firm. Verify the correct LST was provided.

Product Code does not match
The product code transmitted for the entry did not match the product code on file for the listing number transmitted. Verify that the correct LST was provided and/or that the product code matches the LST.

Submission # does not match
The Pre-market notification or Premarket approval (PM#) transmitted for the entry did not match one of the numbers on file for the listing number transmitted. Verify that the PM# provided matches the product being introduced for import.

Firm name does not match
The firm name provided in the entry did not match the firm name on file for the listing number transmitted. Verify that the firm listed on the entry matches the firm used for the LST.

Registration does not match
The registration number provided in the entry did not match the registration number on file for the transmitted listing number. Verify the DEV provided matches the LST provided.

UNK is declared as IUC and the AofC REG supplied instead of DEV
When the Intended Use Code (IUC) is declared as unknown (UNK), inappropriate Affirmation of Compliance (AofC) qualifiers can be transmitted causing a lookup failure. Example: AofC provided was for Drug Registration (REG) not Device Manufacturer Registration (DEV) or Device Foreign Exporter Registration (DFE) as required for a device entry. Make sure when submitting a foreign device registration number that either DEV (manufacturer) or DFE (exporter) is used. 

We understand the complexity of creating and maintaining a seamless compliance process. Contact Mohawk Global Trade Advisors to talk about how we can help you build a better Import Compliance Program.

FDA’s Medical Device Common Entry Errors.

PREDICT Fact Sheet.

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