Author: jameshumphrey

FDA Delays MoCRA Enforcement: A Reprieve for Industry Compliance

In a recent development, the U.S. Food and Drug Administration (FDA) has made a strategic move by announcing the postponement of the enforcement of certain provisions under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA). This decision, aimed at offering the cosmetic industry a grace period, underscores the FDA’s commitment to ensuring a smooth transition toward compliance with the new regulatory landscape.

Understanding MoCRA

MoCRA, enacted in 2022, bestowed the FDA with enhanced authority, particularly in the realms of facility registration and product listing for cosmetic products. The key provisions under MoCRA include:

Facility Registration

Cosmetic product manufacturers and processors are now required to register their facilities with the FDA. This involves periodic updates within 60 days of any changes and a mandatory renewal every two years.

Product Listing

A responsible person, such as the manufacturer, packer, or distributor, must provide the FDA with a comprehensive list of each marketed cosmetic product. This list should include detailed information about product ingredients, with updates required annually.

Navigating Exemptions

MoCRA acknowledges exemptions for certain small businesses, but these do not cover cosmetic products that:

  • Regularly come into contact with the mucus membrane of the eye under customary conditions.
  • Are intended for injection, internal use, or alter appearance for more than 24 hours without consumer removal.

Additionally, exemptions are not applicable to products and facilities subject to requirements for drugs and devices.

Regulatory Milestones

The regulatory journey began in March 2023 when the FDA ceased accepting submissions to the Voluntary Cosmetic Registration Program (VCRP) in response to MoCRA mandates. Subsequently, in August 2023, the FDA released draft guidance on cosmetic product facility registrations and product listings. This guidance, upon finalization, will serve as a valuable resource for those navigating compliance.

September 2023 marked another milestone with the FDA opening an opportunity for public comments on the draft electronic submission portal, Cosmetics Direct, and accompanying paper forms. The push towards electronic submissions reflects the FDA’s commitment to enhancing efficiency and timeliness in data management.

Delayed Enforcement: A Strategic Move

In the latest announcement, the FDA has declared a six-month delay in enforcing the cosmetic product facility registration and product listing requirements. This extension, beyond the statutory deadline of December 29, 2023, extends the grace period until July 1, 2024. The FDA has also clarified that the registration and listing requirements will not be enforced for facilities or products initiated after December 29, 2022, until the revised enforcement date.

Future Forwarding: Staying Ahead of Regulatory Changes

As the regulatory landscape evolves, it is imperative for industry stakeholders, including Future Forwarding, to stay informed about policy changes. Keeping abreast of developments ensures a proactive approach to compliance, reducing the risk of disruptions and ensuring the seamless flow of cargo.

Future Forwarding, with its commitment to staying informed and adapting to regulatory changes, stands as a trusted partner in handling cargo. In this dynamic environment, the ability to navigate evolving regulations is crucial, and Future Forwarding’s dedication to compliance positions us as a reliable choice for businesses seeking a forward-thinking logistics partner. Reach out today. 

Deciphering the Ultimate Consignee

When it comes to importation and navigating the complex web of regulations, it’s essential for freight forwarders and all parties involved to understand their roles and responsibilities. One crucial aspect of this process is determining the ultimate consignee. In this blog post, we’ll explore the concept of the ultimate consignee in import transactions and the Foreign Trade Regulations (FTR) that govern it.

The Ultimate Consignee Defined

The ultimate consignee is the individual, party, or designee located abroad who actually receives the imported shipment. This designation is important because it helps authorities trace the movement and destination of goods in international trade. Whether the goods are intended for sale in the United States or abroad, or they are on consignment, the name and address of the ultimate consignee must be reported in the Electronic Export Information (EEI).

For shipments requiring an export license, such as those headed for international waters, the ultimate consignee should align with the person designated on the export license or authorized to be the ultimate consignee under the applicable license exemption or exception in compliance with the Export Administration Regulations (EAR) or International Traffic in Arms Regulations (ITAR), as applicable.

The Challenges of Identifying the Ultimate Consignee

The determination of the ultimate consignee can be particularly challenging when the end user and the ultimate consignee are distinct entities located in different countries. The FTR defines the ultimate consignee as “the person, party, or designee that is located abroad and actually receives the export shipment. This party may be the end user or the Foreign Principal Party in Interest (FPPI).”

Let’s delve into practical scenarios to shed light on this intricate process:

Scenario 1: The FPPI/foreign buyer receives the goods directly for consumption. In this case, the FPPI/foreign buyer is the ultimate consignee.

Scenario 2: The FPPI/foreign buyer receives the goods but is also involved in further distributing or reselling them. If the FPPI/foreign buyer refuses to disclose its customers, the AES filer should report the reseller/distributor as the Ultimate Consignee Type, with the FPPI/foreign buyer as the ultimate consignee since it’s the entity actually receiving the goods.

Scenario 3: The FPPI/foreign buyer discloses the country of the end user(s) but not the specific customer(s). In this case, the FPPI/foreign buyer is still the ultimate consignee, and the known country of the end user becomes the Country of Ultimate Destination.

Additional Scenarios: More complex scenarios may involve routed export transactions and changes to the goods in inventory or for sale, all of which require careful consideration when determining the ultimate consignee.

How to Ensure Compliance

Importers, including freight forwarders, must ensure they comply with these regulations to avoid potential complications. The best practice is to work closely with U.S. or foreign principal party in interest customers to clarify who should be reported as the ultimate consignee when needed.

Navigating the intricacies of importation, especially when determining the ultimate consignee, can be a challenging task. However, understanding the regulations and working closely with the relevant parties will ensure a smoother process. Future Forwarding is here to help you stay compliant. Contact us today for expert guidance.

Export Controls: Global Security and Russia

In recent years, geopolitical tensions have resulted in stricter export controls on specific items that have the potential to be diverted to support military operations. The Department of Commerce’s Bureau of Industry and Security (BIS) has been at the forefront of implementing stringent measures to curb the illegal use of certain technologies, particularly in the context of Russia’s actions in Ukraine. To help shippers and industry stakeholders stay informed, we present a comprehensive guide to common high-priority items, export control tiers, and the responsibilities of global shippers.

The Common High Priority Items List

Since February 24, 2022, BIS has been actively involved in restricting Russia’s access to technologies and items crucial for sustaining its military operations in Ukraine. These restrictions also apply to Belarus due to its involvement in supporting Russia’s destabilizing activities. BIS has identified 45 “common high-priority items” by six-digit Harmonized System (HS) Codes that Russia seeks to acquire for its weapons programs.

The common high-priority items are categorized into four tiers based on their significance to Russia’s war efforts:

Tier 1: These items are of the highest concern due to their critical role in the production of advanced Russian precision-guided weapons systems. These items lack domestic production in Russia, and there are limited global manufacturers.

Tier 2: This tier includes additional electronic items that Russia may have some domestic production capability for but prefers to source from the United States and its allies.

Tier 3.A: Further electronic components used in Russian weapons systems, with a broader range of suppliers.

Tier 3.B: Mechanical and other components utilized in Russian weapons systems.

Tier 4: Manufacturing, production, and quality testing equipment for electric components, circuit boards, and modules.

Notably, BIS has given special attention to the nine HS codes in Tiers 1 and 2, as they have extensive commercial applications but have also been found in Russian missiles and drones on the battlefield in Ukraine. Items in Tiers 1 and 2 are subject to the most comprehensive controls under the Export Administration Regulations (EAR).

Understanding the Export Control Categories

The items in the 45 HS codes encompass a wide range of technology and components. These items include both lower technology items designated EAR99, as well as more sensitive items on the Commerce Control List (CCL), including items designated under Export Control Classification Numbers (ECCNs). Some of the ECCNs include 3A001, 3A002, 3A090, 3A991, 3A992, 3B001, 3B991, 3B992, 5A001, 5A991, 6A002, 6A003, 6A993, 7A003, 7A994, and 9A991.

Exporters and shippers dealing with these items need to be aware of the potential risks and compliance requirements, given the sensitive nature of these technologies and components.

Export Control Risks

Russia’s efforts to procure these high-priority items pose significant risks for individuals and entities, both inside the United States and globally. Inadvertent involvement in violations of U.S. export controls and sanctions laws can lead to severe civil or criminal liability. Additionally, foreign parties engaged in activities contrary to U.S. foreign policy and national security interests may be added to BIS’s Entity List or OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List.

Russia often employs evasive tactics such as third-party intermediaries or transshipment points to obscure the true identities of end-users and circumvent restrictions. Exporters, reexporters, and their service providers, including financial institutions, logistics companies, and transportation providers, need to be vigilant and take appropriate measures to mitigate these risks.

Guidance from BIS and U.S. Government Agencies

BIS and other U.S. government agencies have issued various guidance documents to assist industry stakeholders in understanding and addressing these export control challenges. These documents include:

  • An alert issued by FinCEN and BIS urging increased vigilance for potential Russian and Belarusian export control evasion attempts.
  • Frequently asked questions for exporters on commodities and red flags identified in previous alerts.
  • Tri-Seal Compliance Note jointly issued by the Department of Commerce, Department of the Treasury, and Department of Justice, aimed at cracking down on third-party intermediaries used to evade Russia-related sanctions and export controls.
  • A supplemental alert addressing potential Russian export control evasion attempts on the highest-priority nine HS codes.
  • BIS guidance specifically tailored to exporters and reexporters for the nine highest-priority HS codes.
  • Guidance from various U.S. government departments and agencies on items sought by Iran for the production of Unmanned Aerial Vehicles (UAVs) and the need to counteract Russia’s procurement efforts.

United States-Australia-Canada-New Zealand-United Kingdom Joint Guidance

The “Export Enforcement Five” or “E5” partnership, established in June 2023, comprises the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States. These nations are working together to coordinate export control enforcement and combat Russia’s evasion tactics.

The E5 partnership has issued joint guidance to industry and academia, identifying high-priority items critical to Russian weapons systems and recommending actions to prevent their diversion to Russia through third countries. This collaborative effort emphasizes the importance of global cooperation in curbing illegal procurement of sensitive technologies.

Navigating the complex landscape of export controls is crucial for maintaining global security and stability. Shippers and industry stakeholders must remain informed about the common high-priority items and the stringent export controls associated with them. By adhering to compliance measures and staying vigilant, we can collectively contribute to global efforts to combat the illegal use of sensitive technologies and support international peace and security. For more detailed information and the full guidance document, please visit here. 

 

At Future Forwarding, we are committed to helping our customers navigate the ever-changing landscape of international shipping and export controls. If you have questions or require assistance with your shipments, please don’t hesitate to reach out to our dedicated team of experts. Rest assured, we stay on top of the latest policy developments and industry updates to provide you with the most accurate and up-to-date guidance. Your peace of mind and the success of your shipments are our top priorities. Contact us today to experience the future of forwarding and ensure your shipments comply with all relevant regulations. Your journey to seamless and compliant international shipping begins with us.

Enhancing Shipping Efficiency: Future Forwarding’s Partial Truckload Domestic Service

In the intricate world of logistics, companies continually seek innovative approaches to streamline their shipping operations. One recurring challenge is finding the perfect solution for shipments that fall within the middle ground, not quite qualifying as Less Than Truckload (LTL) but not warranting a Full Truckload (FTL) either. Enter Future Forwarding‘s Partial Truckload Domestic Service (which includes Canada), a tailored and cost-effective shipping solution that bridges this gap, offering efficiency and savings.

Unlocking the Potential of Partial Truckload

Partial Truckload, often referred to as “volume LTL,” caters to larger shipments that do not require the entirety of a truckload trailer. It fills a crucial niche, accommodating shipments exceeding 5,000 pounds or comprising six or more pallets. In contrast to LTL, partial truckload shipments simplify the pricing structure by not necessitating freight class classification, thereby avoiding potential extra charges associated with reclassification.

Efficiency Amplified: One-Truck Transit

One of the principal merits of embracing Future Forwarding’s Partial Truckload Domestic service is the streamlined efficiency it injects into your shipping process. Unlike LTL, where shipments might undergo multiple handling stages at various terminals, partial truckload ensures that your cargo stays on a single truck for the entire journey. This translates to reduced handling, a diminished risk of damage, and expedited deliveries. With cargo loaded and unloaded only once, the probability of mishandling or damage during transit is significantly minimized.

When to Leverage Partial Truckload

Partial truckload proves advantageous in diverse shipping scenarios:

  • Low Density Freight: If your shipment is lightweight but consumes considerable space, partial truckload offers a more efficient solution than LTL.
  • Fragile Cargo: When concerns arise about the safety of your goods during handling, the reduced handling associated with partial truckload shipments significantly reduces the likelihood of damage.
  • Cost Efficiency: Partial truckload pricing is based on the space and weight capacity utilized, making it a cost-effective choice in comparison to other shipping methods.

Frequently Asked Questions about Partial Truckload

Here are some commonly raised queries concerning partial truckload shipping, along with informative responses that illuminate the intricacies of this effective shipping modality:

  • When is partial truckload preferable over LTL? Partial truckload is the cost-effective choice for shipments surpassing 5,000 pounds or incorporating six or more pallets, especially when LTL relies on freight class, potentially elevating costs for space-intensive, low-density shipments.
  • Is precise knowledge of dimensions essential? Yes, precise dimensions are imperative. Carriers mandate accurate measurements to ensure your cargo snugly fits within the trailer’s confines.
  • Does partial truckload deliver faster transit times compared to LTL? Yes, typically. Partial truckload minimizes the frequency of stops at freight terminals, bypassing LTL cross-docking, culminating in speedier transit.
  • How do I know if partial truckload aligns with my needs? Future Forwarding offers complimentary, real-time quotations and an adept team to guide you in determining the best shipping solution for your specific requisites.
  • How does partial truckload fundamentally differ from LTL? The crux of the distinction lies in pricing and handling. Partial truckload pricing hinges on weight and size considerations, whereas LTL factors in freight class and density, potentially yielding distinct cost structures.

Experience the Future of Domestic Shipping with Future Forwarding’s Partial Truckload Domestic Service

In the ever-evolving logistics domain, having flexible shipping solutions at your disposal is paramount. Future Forwarding’s Partial Truckload Domestic Service is your key to a reliable, efficient, and cost-effective alternative for shipments that straddle the line between LTL and FTL. By opting for this service, you can harmonize your shipping operations, diminish the vulnerability of damage, and ultimately save both time and money. Reach out to Future Forwarding’s Domestic Team (dt@usffcl.com) today and embark on a journey into the future of domestic shipping.

 

Preparing for Lacey Act Phase VII: Your Guide to Ensured Compliance and Sustainable Trade

The Lacey Act, originally enacted in 1900 to combat bird poaching, has evolved significantly over the years. In 2008, the Farm Bill brought substantial amendments to the Act, extending its protections to a broader range of plants and plant products. These amendments aimed to tackle issues like illegal logging and the unlawful harvesting of wild plants, which are often linked to terrorism, deforestation, political instability, and illegal trade. Today, the Lacey Act plays a crucial role in safeguarding forests, wildlife, and people globally by regulating the importation of certain plants and plant products into the United States.

What Is the Lacey Act?

The Lacey Act requires importers to submit a Lacey Act declaration when importing certain plants and plant products into the United States. This declaration is essential for ensuring that imported plant materials have been legally harvested and traded. The declaration must include detailed information, such as the scientific name of the plant, the importation’s value, quantity, and the country of origin.

Over the years, the Act has undergone several phases of implementation. The most recent development is Phase VII, set to roll out soon. This phase will expand the list of materials and plant products that require Lacey Act declarations, impacting a wide array of imported items like furniture, essential oils, and cork, which have not previously needed such declarations.

Preparing for Phase VII

The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) will soon announce the schedule for Phase VII of Lacey Act declaration implementation. To prepare for these changes, here’s what importers need to do:

  • Know Your Supply Chain: Familiarize yourself with your supply chain for each piece of plant material in the product you import. Ensure that the materials have been legally sourced and documented.
  • Learn How to File a Declaration: Understand the process of filing a Lacey Act declaration. This can be done electronically through the Automated Commercial Environment (ACE) or the Lacey Act Web Governance System (LAWGS). Review the guidelines provided by APHIS to ensure a smooth declaration process.
  • Read Frequently Asked Questions: Explore the frequently asked questions (FAQs) provided by APHIS to clarify any doubts you may have about Lacey Act compliance.
  • Stay Connected: Stay updated on the latest developments and announcements related to the Lacey Act by keeping in touch with APHIS through their official channels.

Who Needs a Lacey Act Declaration?

If you import items containing plant products and your products fall under specific Harmonized Tariff Schedule (HTS) codes listed on APHIS’ Implementation Schedule, you are required to submit a Lacey Act declaration. However, there are exceptions, and you may not need a declaration if your product meets certain criteria:

  • Common Cultivars, except trees
  • Common food crops
  • Scientific specimens of plant genetic material used solely for laboratory or field research
  • Plants that will remain planted or will be replanted
  • Packaging materials, such as wood crating, pallets, cardboard boxes, and packing paper (unless the packaging material itself is the imported item)
  • Plant material representing no more than 5 percent of the total weight of the individual product unit, provided it does not exceed 2.9 kilograms for entries within the same 10-digit tariff provision

Penalties for Non-Compliance

Compliance with the Lacey Act is crucial, as non-compliance can result in civil or criminal penalties. Civil penalties can range up to $250 for violations, while criminal penalties can be much more severe, including imprisonment for up to five years and substantial fines.

The Lacey Act plays a vital role in protecting forests, wildlife, and the environment from illegal trade and exploitation. As Phase VII approaches, importers must prepare to comply with the expanded declaration requirements. By understanding the Lacey Act’s provisions, knowing your supply chain, and staying informed, you can ensure a smooth transition, contribute to the preservation of our planet’s natural resources, and keep your cargo moving.

If you have any questions, feel free to reach out and let us guide you. 

 

The Atlantic Declaration: Strengthening Trade and Economic Partnership Between the US and UK

In a significant move to bolster economic ties and address pressing global challenges, the United States and the United Kingdom have announced the Atlantic Declaration. This collaborative effort, hailed as the “first of its kind,” focuses on fostering cooperation in various sectors, including clean energy, critical minerals, and artificial intelligence. With a shared commitment to economic growth, supply chain resilience, job creation, and technological advancement, the two nations aim to adapt and reimagine their alliance.

 

Pillar 1: Ensuring U.S.-UK Leadership in Critical and Emerging Technologies

Recognizing the importance of critical and emerging technologies, such as semiconductors, quantum technologies, and artificial intelligence, the US and UK are committed to leading in these sectors. The partnership will involve joint research and development efforts, public-private dialogue, mobilization of private capital, and talent flows. By collaborating on these technologies, both countries can drive innovation, economic growth, and job creation while safeguarding their national security interests.

 

Pillar 2: Advancing Ever Closer Cooperation on Technology Protection and Supply Chains

To address evolving national security risks and protect sensitive technologies, the US and UK will align and update their regulatory frameworks. This includes export controls, investment screening, sanctions, and research and development security. By coordinating their efforts, both nations aim to prevent the leakage of emerging technologies and enhance information sharing on threat intelligence. The focus on technology protection and resilient supply chains will strengthen trade relations and ensure economic security.

 

Pillar 3: Partnering on an Inclusive and Responsible Digital Transformation

As digital transformation becomes increasingly vital for economic growth, the US and UK are committed to working together on an inclusive and responsible approach. By fostering collaboration in areas such as 5G and 6G telecommunications, synthetic biology, and AI safety, both countries can drive innovation while addressing societal concerns and ethical considerations. This partnership will promote a thriving digital economy and provide opportunities for businesses and workers on both sides of the Atlantic.

Pillar 4: Building the Clean Energy Economy of the Future

Recognizing the need to transition to clean energy, the US and UK will collaborate on clean energy technologies, infrastructure development, and reducing reliance on Russian fuel in the civil nuclear sector. By investing in clean energy industries and strengthening supply chains, both nations can drive sustainable economic growth, mitigate climate change, and create new employment opportunities in the energy sector.

 

Pillar 5: Strengthening Alliance Across Defense, Health Security, and Space

The Atlantic Declaration also emphasizes the importance of deepening the alliance between the US and UK across defense, health security, and space. By leveraging their expertise and resources, both nations can enhance global security, respond to emerging health threats, and collaborate on space exploration and research. This multifaceted cooperation further strengthens the economic partnership by fostering cross-sector collaboration and knowledge sharing.

 

The Atlantic Declaration marks a significant milestone in the economic partnership between the United States and the United Kingdom. By focusing on critical and emerging technologies, technology protection, digital transformation, clean energy, and defense cooperation, both nations seek to drive economic growth, job creation, and shared prosperity. This collaborative effort sets the stage for future advancements in trade, innovation, and sustainable development. 

 

Ready to experience the future of logistics excellence? Reach out to Future Forwarding today and let us be your trusted partner in achieving seamless supply chain operations. Whether you need full-service logistics support or assistance in specific areas, we have the expertise and dedication to meet your needs.

Great Customer Experience Starts With the Right Tools

A great customer experience starts with a specifically curated list of assets, the most important of those being great people. Then providing those people with the tools, education, and context they need to use them to best serve the customer. 

 

For example, the brokerage, forwarding, and quotes teams at Future Forwarding all are focusing on CCS completion. The Certified Customs Specialist (CCS) Certification Program is designed to assist trade professionals involved in the import industry to become experts in the current import regulations. The MCS (Master Customs Specialist) designation is the next level certification of knowledge of advanced compliance topics, and is awarded only to a select group of knowledgeable individuals nationwide. Both are recognized by industry professional colleagues and accredited by the National Customs Broker and Freight Forwarders Association (NCBFAA) National Education Institute (NEI). Once passing the CCS exam, each individual is required to complete over twenty CEU hours annually to maintain the designation. 

 

This gives our teams an advantage. This extra level of job knowledge achieved by cross-training other departments improves our quoting and shipping reliability. The team knows to ask questions about specific commodities subject to high duty or release by partner government agencies in the quotes and shipping process. Not only does that strengthen our stance on compliance and continued education, but it makes us more efficient and ensures that you’re getting optimized service every step of the way. 

 

With an ever-changing industry, it’s important to stay up to date on regulatory requirements and market conditions, and have a trusted logistics partner who will keep you informed, compliant, and your cargo moving. 

Meet a few of the team members who make that happen. Cody Chatman, Brokerage (CCS), McKenzie Bonner, Forwarding Dept (CCS), Veronica Windisch, Quotes Team (CCS), Jeremiah Hill, Forwarding Dept (CCS), Kristhian Vejarano, Brokerage Supervisor (MCS). And not pictured is Heather Stalvey, Quotes Team (CCS). Put yourself in their capable hands and let them guide your success. 

 

What Is Happening in Congress

Congress has seen a major effort meant to empower the shipping industry’s regulator and strengthen the hand of shippers introduced in the Senate. The Ocean Shipping Reform Act (OSRA) has been introduced in the Senate after passing the House in remarkably bipartisan fashion, 364-60. The bill’s aim is to give more power to the FMC and take action against those engaging in anti-competitive behavior, which has resulted in a negative impact on US importers, exporters, and retailers. The proposed changes also require carriers to meet minimum service standards. 

 

The goal of the Ocean Shipping Reform Act of 2021 (H.R.4996) is:

  • Establish reciprocal trade to promote U.S. exports as part of the Federal Maritime Commission’s (FMC) mission.
  • Require ocean carriers to adhere to minimum service standards that meet the public interest, reflecting best practices in the global shipping industry.
  • Require ocean carriers or marine terminal operators to certify that any late fees —known in maritime parlance as “detention and demurrage” charges—comply with federal regulations or face penalties.
  • Shift burden of proof regarding the reasonableness of “detention or demurrage” charges from the invoiced party to the ocean carrier.
  • Prohibit ocean carriers from declining opportunities for U.S. exports unreasonably, as determined by the FMC in new required federal rulemaking.
  • Require ocean common carriers to report to the FMC each calendar quarter on total import/export tonnage and twenty-foot equivalent units (loaded/empty) per vessel that makes port in the United States.

 

Focusing on detention and demurrage that predated the pandemic, the main concern leveled on this new bill is that it misses the point of the complaints about inability to ship cargo during the pandemic. The main concerns surrounding disruption in the supply chain on a historic level have not been addressed, though the bottlenecks have moderately abated when the White House put intense political pressure on carriers and terminals to get the flow moving. 

 

The House of Representatives also passed the America Creating Opportunities for Manufacturing Pre-Eminence in Technology and Economic Strength (America COMPETES) Act on February 4, 2022. Contained in this legislation are:

 

  • The reinstatement of the Generalized System of Preferences, retroactive to December, 31, 2020.
  • Providing for two cycles of the Miscellaneous Tariff Bill.
  • Imposing restrictions on the use of the Section 321 “de minimis” exemption for non-market economies like China.

 

For both bills, the Senate will face pressure from interests to water down or remove provisions from the House bill. Ocean carriers do not want to be exposed to violations for incorrect demurrage and detention bills – a common occurrence right now. With the COMPETES Act, companies have made major changes to take advantage of the de minimis rule and e-commerce platform operators and e-tailers would have a seismic shift in returning to processes that included holding inventory in the US and paying ad valorem duties and – more importantly right now – Section 301 duties on many of those items.

 

We will continue to monitor these two pieces of legislation and update clients on what ultimately is agreed to and passed through Congress.

FUTURE FORWARDING AND REVERSE LOGISTICS

Because shipments are now leaving warehouses for consumers rather than exclusively distribution centers or retailers, the need to have a process for managing customer-level returns is of increasing importance to e-Commerce sellers. An entire association has in fact come into being because of this need. Reverse logistics management is one of the most rapidly growing sectors of e-Commerce management and fulfillment.

 

The buying and return management needs of goods owners in sectors such as footwear and apparel are far different because their customers are buying differently than a company selling home furnishings or consumer electronics. Garment and footwear importers and cargo owners cannot rely on a one-size-fits-all returns solution offered by just any provider. The specific returns management solutions that Future Forwarding offers differentiate us from the competition.

 

As detailed in this recent BBC article, consumers who are choosing not to go to stores – or who pre-pandemic were already purchasing these items online – may be unsure of the size they need. Instead of buying one, they may buy two, three or even five versions of the same garment or shoe, bracketing a range of sizes to find the one that fits just right. 

 

For the seller, it means carrying additional inventory and carefully forecasting their selling price to accommodate the inherent cost of processing a return of 50 – 80% of the initial shipment. 

 

For the logistics company, it increases the number of picks for a single order and creates a bidirectional flow of freight into and out of their warehouse, including designing a process to inspect, repackage and prepare a product to leave the warehouse for a second or perhaps even third time.

 

Future Forwarding has at its core deep experience in handling reverse logistics for garment and footwear importers. We have designed systems that involve inventorying, picking and shipping seasonal orders to traditional brick and mortar stores operated by department stores as well as the brands themselves. At the end of a season, items may be returned to be cleaned, hung, have small repairs made and bide their time to go back out the next year. 

 

The same systems that we use to send and receive these large pick-and-ship orders are immediately translatable to individual e-Commerce orders destined directly for the purchasers. 

 

  • We maintain comprehensive on-hand and inbound inventory visibility at style, size and SKU level. This ensures accuracy for online stories and also helps the cargo owners determine whether or not a single or multiple shipments will be required to fulfill a single order.
  • Future Forwarding has designed and optimized our warehouses and deployed technology for our employees that allows them to receive, prioritize and fill orders using rules that we or our customers have set.
  • Our locations in the Atlanta metropolitan area put us within immediate reach of a significant percentage of our customers’ audiences in as little as three days for most ground-based parcel services.
  • We have garment-on-hanger and footwear specific racking.

 

There are warehouses who talk about e-Commerce fulfillment and their ability to pick and pack for garment and footwear companies – and then there is Future Forwarding.

 

Contact us today for a virtual or in-person tour of any of our buildings or to learn how we can become your e-Commerce fulfillment provider on the back of our strength in return logistics management.

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