international trade affairs & compliance - district … express usa carnet shipments page 3 dhl...

Phillip Poland, Director Export Controls & Trade Integrity

Temporary Export and Import Shipments

International Trade Affairs & Compliance

DHL EXPRESS USA Carnet Shipments

Outline

I. DHL Express USA

II. Temporary Exports from US Under Carnet

III. Temporary Imports to US

IV. Other Temporary Export Issues

V. Common Mistakes


DHL Express (USA) Inc.

DHL Express was founded in 1969 in San Francisco, USA by Dalsey, Hillblom

and Lynn.

– The first express delivery service provider, predates FedEx

– Entered international markets before our competitors (Asia from the start,

Europe-’74,LA in ’77, ME/Africa in ‘78 Asia, Eastern Europe in 1983)

– Over 225 countries and territories served and globally, DHLE delivers over

2 billion shipments a year to 120,000 destinations.

– A true global network that includes Cuba, Syria, Sudan, North Korea and

Myanmar

Now part of the Deutsch Post World Net AG group

– The group serves over 5 million customers with over 250,000 employees

around the globe

– DHLE (USA) is now focusing just on international service with main int’l

gateways in LAX, NYC, MIA, ILN, and SFO


DHL Express USA

Express Benefits

• Prepares and files all necessary Customs documentation for

goods entering the United States.

• On-site customs inspection services aligned to our flight

schedules to ensure next day delivery

• Security and peace of mind because we have full operational

control and visibility of the shipment.


DHL Express’ Global Customs Vision

To be recognized as the global Leader, providing

transparent, harmonized and cost effective

customs procedures that meet the needs of our

customers, the company and the authorities.


Outline

I. DHL Express USA




V. Common Mistakes


Initiate the Temporary Export from the U.S.

Completing the Air waybill

• In Description specifically list “CARNET” or “Temporary”

• Other important items that should be listed on waybill:

• TMP for DOC Goods or DSP-73/exemption for ITAR

• Indicate true value of goods

• Schedule B Number

• AES ITN or Exemption

• Check “Temporary”

15 CFR § 30.37 provides exemption to filing EEI under 30.37(q)

for Carnet Shipments. No EEI 30.37(q) **


Export Waybill from the U.S.

Add “Carnet” to

description

Indicate:

TMP for DOC

DSP-73 for ITAR

“No EEI 30.37(q)

Check

Temporary


Carnet Export AES Exemption – DHL Webship

Step 2: Place exemption note in Section 1.


Commercial Invoices

Contains important information for customs clearance like:

• Tax identification numbers

• Licenses numbers / exemption number

• Identification of parties to the transaction, including third party

agents for clearance or payment of taxes, duties, or other fees

• Complete classification and description of the goods

• Incoterms that cover the transaction

Under U.S. export regulations the commercial invoice for any

goods subject to the Export Administration Regulations (“EAR”)

or the International Traffic in Arms Regulations (“ITAR”) must

have a specified “Destination Control Statement”.


Export Waybill from the U.S. – DHL Webship

Enter Shipment

Comments on

Commercial invoice.

Insert “CARNET”


Important Carnet Information

Retain a copy of Carnet and AWB for internal recordkeeping.

***Note, retaining a copy of the Carnet with most up to date

stamps is strongly recommended.


Carnet Export from the U.S.

• Place the following in pouch directly on package:

• ORIGINAL Carnet

• ORIGINAL Carnet General List

• Commercial Invoice

• Service Alert Label

Orange labels can be

procured through your

sales rep or at the

nearest DHL Express

service station.


Pre-Alert Your Shipment

Pre-alert DHL Express of Carnet Shipment:

Send Email to DHL prior to shipment pickup/drop-off:

[email protected]

Include:

• Air waybill #

• Shipper name

• Destination

• Contact information

• Number of packages

mailto:[email protected]


Outline

I. DHL Express USA




V. Common Mistakes


Temporary Imports to the U.S.

Ensure the first word of the description is CARNET

Ensure Carnet is received

• Often recommend sending it

Once a carnet shipment arrives into the U.S.:

• DHL will need a customs Power of Attorney.

• DHL will have the Carnet stamped.

• Package will be delivered.

• DHL will contact customer for instructions on the Carnet.


High Value or Restricted Commodity Process

High value shipments and Restricted Commodity Shipments will need

approval prior to inducting into DHL Express Network.

• High value shipments are valued over $100,000.

• Restricted commodities include:

• Negotiable Instruments

• Furs & Ivory

• Jewelry Including Watches, Precious Metals or Stones

• Firearms, and Items which could be used as weapons

• Live animals (including insects, larvae, pupae, etc)

• Medical Samples

• Tobacco

**Contact sales representative to

obtain approval prior to sending

shipment.**


ITAR Import Issues

• Import must clearly cite license or exemption

• Canada has its own temporary exemption

• Licenses must be decremented at both import and export

• The import must be done correctly to do the corresponding

export correctly

• Required language on documents

U.S. Goods Returned

This import shipment is being imported in accordance with

and under the authority of _____ (list exemption)


Outline

I. DHL Express USA



IV. Other Temporary Export/Import Issues

V. Common Mistakes


ITAR Import Decision Tree

ITAR Part 123.4 (a) US Origin Items:

(1) Is Serviced and Subsequently Returned to

the Country From Which It Was Imported.

(2) Is to Be Enhanced, Upgraded, or

Incorporated Into Another Article Which

Has Already Been Authorized by DDTC for

Permanent Export.

(3) Is Imported for Purpose, Exhibition,

Demonstration or Marketing in the U.S.

and Is Subsequently Returned to the

Country From Which It Was Imported

(4) Has been Rejected for Permanent Import

by Department of Treasury and Is Being

Returned to the Country From Which It

Was Shipped

(5) Is Approved for Import Under FMS

US Origin ?

Yes No

Canadian Origin

126.5(a)

Incorporate or Modify

123.4(b)

Other Foreign Origin

Repair or Replace

DSP-61

List “U.S. Goods Returned” if applicable

List license or exemption if applicable


ITAR Export Issues

• AES filing is required for all ITAR controlled shipments

• For the corresponding export to a temporary import you must

list the entry summary number

• The export documents must cite the license or exemption

• Canada has its own temporary exemption

• The consignee at the time of export listed on the documents

and in AES needs to match the parties listed at the time of

importing the goods

• Licenses must be decremented at both import and export


Electronic Export Filer Tool

First Log On to the website

http://www.dhl-usa.com/home/home.asp

Select the Electronic Export Filer





Outline

I. DHL Express USA




V. Common Mistakes


Most Common Problem By Shippers

Too Much Trust In Your Freight Forwarder

• Company relies on your freight forwarder for record keeping and not

keeping your own records

– Remember that the regulations state that the any (all) parties to

the transaction are required to keep records

– See 22 CFR § 122.5, 15 CFR § 30.10(a), and 15 CFR § 762.1 for

record keeping rules

– This includes the USPPI in a routed transaction


Ensuring Accuracy of Filing

• Provide the most complete information possible to agent or in-house

staff doing the filing

• Request records from your filing agent

• Audit filings periodically to verify that the information provided to the

U.S. Government matches the commercial invoice, export license,

POAs, and any other contractual and transaction documentation

related to the shipment

• Following up on possible issues before it is too late

• Use AES record data provided by Census to verify internal records

• Contact the carrier or forwarder if self filing to ensure you have the

accurate port of export and carrier code


Most Common Mistakes

Carnet Shipments

• Putting Carnet with invoice on shipment

• Not stating Carnet in the description or comment field

• Fail to maintain copies of records or request records for agent

Repair and Return Temporary Imports/Exports

• Failing to include ITN on the face of the AWB or thermal label

• Failing to cite entry summary number on the corresponding export to a temporary import

• Value for repairs is the value of the repair parts and labor only


Root Cause of Common Mistakes By Shippers

• Not understanding your freight forwarder’s or carrier’s processes and

procedures related to documentation and filings

• Shipping clerk uses the wrong exemption codes or other information

on shipping documentation

• Not taking time to verify that all your documents match

• Not providing your agent all the information that they need

• The party creating the shipping documents is different from the group

filing the EEI in AES, and possibly a different group than who is

packaging the shipment – No one overseeing the overall process

• Not utilizing the most up to date Schedule B or HTS Code

• Shipping staff do not understand – WHY!! or the regulatory basis


Contacts

Questions about Import/Export Regulations:

[email protected]

1.859.817.8010

Tracking and Tracing:

1.800.CALL-DHL

mailto:[email protected]


THANK YOU FOR

YOUR ATTENTION

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