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Protecting the Border Is An Immense Job
Every day, 60,000 CBP employees protect nearly 7,000 miles of land border and 328 ports of entry.
…So Is Managing Our Massive Imports & Exports
In FY 2014, CBP processed $2.4 trillion in imports and $1.6 trillion in exports.
Centers of Excellence & Expertise
collaboration with the trade on streamlining our trade process is the
development of the Centers of Excellence and
February 2015
8 8
Respond to the dynamic trade environment
Bring all of CBP expertise together on a single industry at the national level
Deliver greater consistency and harmonization
Align CBP processes with modern business practices
Enhance industry-based knowledge
Implement manage-by-account practices
Why Centers?
Intellectual Property Rights
Anti-Dumping Countervailing
Duties (ADCVD)Import Safety
Textiles
Revenue
Agriculture
Trade Agreements/Preference Programs
Trade Complexity
9 9
What are Centers? Virtual organizations that leverage
technology to bring work to the Center
Coordinated from a strategic location
Aligned by key industry sectors
Bring existing expertise together to authoritatively facilitate trade
Provide a single point of processing for participating importers
Serve as resource to the broader trade community and to CBP’s U.S. government partners
CEE
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How Centers Operate
• ACME Apparel was importing into 60 Ports of Entry (POE), with 60 ports conducting reviews.
• Instead of 60 ports making decisions on ACME Apparel entries, they would now be reviewed by the Apparel, Footwear & Textiles Center of Excellence which is coordinated from San Francisco, CA.
Previously Center Operations
San Francisco Apparel,
Footwear & Textiles
Los Angeles Electronics
Laredo Machinery
Centers of Excellence and Expertise
Houston Petroleum,
Natural Gas & Minerals
Miami Agriculture &
Prepared Products
Atlanta Consumer Products &
Mass Merchandising
Chicago Base Metals
Detroit Automotive &
Aerospace
Buffalo Industrial &
Manufacturing Materials
New York Pharmaceuticals,
Health & Chemicals
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Action Benefits Eliminate unnecessary transactional work for compliant importers
• Fewer cargo delays • Reduced costs • Greater predictability
Shift focus at Ports of Entry to high-risk shipments
• More complex enforcement work for highly skilled CBP employees • Improved enforcement results:
Increased import safety Increased revenue protection Reduced economic loss to IPR theft
Provide Centralized Point of Contact for inquiries
• Improved relationship with CBP as small/medium-sized importers have a streamlined inquiry process for resolving concerns • Increased uniformity and transparency for the trade
Develop cross-functional expertise
• Environment for in-depth learning to increase CBP expertise and enhanced enforcement methods
Benefits of Centers
Expansion of Centers Operational Expansion Beyond Test Process for 3 Centers Electronics; Petroleum, Natural Gas & Minerals; Pharmaceuticals, Health
& Chemicals Provides for Full Test of Trade Processes Complete Roll Out Within 6-8 Months
Delegation Order Provides Center Directors Full Authority to Make Trade Decisions
Import Specialist Realignment
Expansion of 7 Centers under Center Test Staff Will Transition to Centers as Account Participation Increases Based
on Workload
For official use l
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Roll-Out Timeline and Location Accelerated Roll-Out Timeline
Field Office Phase I Jan-March Phase II April-June Phase III July-Sept
Elec Petro Pharma Elec Petro Pharma Elec Petro Pharma
Atlanta X X X
Baltimore X X X
Boston X X X
Buffalo X X X
Chicago X X X
Detroit X X X
El Paso X X X
Houston X X X
Laredo X X X
Los Angeles X X X
Miami X X X
New Orleans X X X
New York X X X
Portland X X X
San Diego X X X
San Francisco X X X
San Juan X X X
Seattle X X X
Tampa X X X
Tucson X X X
Total # of FO's 6 7 4 5 4 5 9 9 11
Phase I Ports Phase I Ports Phase I Ports
Electronics Center Director
Pharmaceutical, Health & Chemicals Center Director
Petroleum, Natural Gas & Minerals Center Director
Long Beach El Paso Seattle Los Angeles/LAX
New York Blaine
Chicago Newark Pembina Cleveland Chicago Great Falls Milwaukee Cleveland San Francisco Minneapolis Milwaukee Honolulu St. Louis Minneapolis Portland, OR San Francisco St. Louis Long Beach
Honolulu Atlanta Los Angeles/LAX Houston Charleston San Diego Dallas/Ft. Worth
Charlotte Nogales
Seattle Norfolk Phoenix Pembina El Paso Blaine Great Falls Portland, OR Anchorage
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Apparel, Footwear and Textiles Import Highlights
$126.5 billion in footwear, textile, wearing apparel products come into the U.S. (5.5% of all imported value)
Top 5 countries of origin account for 66% of these imports China Vietnam India Mexico Indonesia
Over 64,000 entities import footwear, textiles and wearing apparel 378 entities are ISA (23.9% of imported value) 3,144 entities are C-TPAT partners (62.1% of imported value)
Apparel, Footwear & Textile Center of Excellence & Expertise
CEE Director Dora Murphy
Deputy Director Vacant
Assistant Director Enforcement
Branch Chief
Core Members: Import Specialist Senior Import Specialists Program Manager
Matrix Members: Asst. Port Director International Trade Specialists Operation Specialists Senior Import Specialists Import Specialist Supervisory Import Specialists Supervisory International Trade Specialist Auditor Field Analysis Specialist Supply Chain Security Specialists
Assistant Director Validation & Compliance
Vacant Assistant Director Partnership
Branch Chief Vacant
Core Members: Import Specialists Senior Import Specialists Entry Specialists Supervisory Entry Specialist National Account Managers
Matrix Members: Import Specialists Senior Import Specialists Supervisory Import Specialists National Import Specialist Asst. National Import Specialist
Branch Chief
Laboratories and Scientific Services Primary Center Technical Advisor
Alternate Center Technical Advisors HQ Science Officer
Branch Chief
AFT CEE Enforcement
Enforcement activity can take place at time of entry or at post-release
• Intellectual Property • Free Trade Agreements • Revenue evasion • Transshipment
Some main areas of focus include, but are not limited to the following:
Enforcement actions involving participating accounts are coordinated with the Center prior to issuance.
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AFT Enforcement Focus on areas of risk
Intellectual Property Rights 38% of all FY 14 IPR seizures were wearing apparel/footwear/textile
related. Nearly 9,000 seizures with MSRP of $171 million in FY14.
AFT CEE Enforcement Operations The goal of the operations are
to facilitate legitimate trade
while enforcing the
laws and regulations
against violators.
In addition, operations focus on
protecting our participating
accounts from illegal
importing/exporting of their products.
The AFT CEE works with the participating accounts to
establish concepts/plans
for future operations.
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AFT CEE IPR Enforcement
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Conducted Multiple IPR Operations with Hundreds of
Seizures with total MSRP value over $17 million.
Participated in several National/Local IPR
Operations
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Textile Enforcement OPERATION SUPER FAKE
Intellectual Property Rights
Intercepted 700 shipments of counterfeit merchandise valued at $12 million as part of a Super Bowl XLIX focused operation
conducted on Jan. 26-29 at the DHL facility in Cincinnati.
IPR Recordation The AFT CEE recommends all registered Intellectual Property is recorded with CBP.
All product manuals with recorded trademarks can be submitted to CBP for inclusion in our internal Product ID Guide.
The IPR Product ID Guide allows all CBP personnel (e.g., Officers, Import Specialists, Entry Specialists, etc.) immediate access to the recorded trademarks.
The IPR Product ID Guide is only for CBP use and can not be viewed by outside stakeholders.
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AFT Enforcement Focus on areas of risk
Revenue Duty collected by CBP on footwear, textile and apparel goods still
accounts for approximately 45% of all duties The average duty rate for textile, apparel and footwear is 17% and
more than $17 billion of entered textiles and wearing apparel claim preferential tariff treatment, placing textiles and apparel at a high risk for non-compliance.
Misclassification and undervaluation are schemes to evade high duty rates on textiles and footwear
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AFT Enforcement Focus on areas of risk
Trade Agreements
17% of imported value claims preferential treatment False preferential claims undermine trade agreements
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Textile Enforcement Focus on areas of risk
Trade Agreements There are 14 Free Trade Agreements. Australia (AFTA); Bahrain
(BFTA); Chile (CFTA); Central America – Dominican Republic Free Trade Agreement (CAFTA); Israel (ILFTA); Jordan (JFTA); Morocco (MFTA); North American Free Trade Agreement (NAFTA); Oman (OFTA); Peru (PTPA); Singapore (SFTA); Korea (UKFTA): Colombia (CTPA); Panama (PATPA)
There are also several Special Trade Programs with various
countries, they are as follows: African Growth and Opportunity Act (AGOA); Caribbean Basin Trade Partnership Act (CBTPA); Caribbean Basin Economic Recovery Act (CBERA) and Generalized System of Preferences (GSP). Currently, GSP is expired.
CBP utilizes Textile Production Verification teams (TPVTs) to conduct on-site verification of foreign textile and wearing apparel manufacturers.
These teams review and verify production capability and compliance with the terms of FTAs and trade preference programs.
The TPVT visits help deter circumvention of the preference program requirements, as well as educate foreign governments and manufacturers.
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On-Site Verification
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Center and Industry Partners work collectively to define low-risk suppliers and
sharing trade intelligence to better define and segment high-risk suppliers.
The Center’s national approach is assisted through leveraging the Commercial Targeting and Analysis Center (CTAC) in Washington, DC. • Established in 2009, CTAC serves as CBP’s multi-agency
fusion center for targeting commercial shipments which pose a threat to health and safety.
• Nine (9) Federal agencies co-located : CPSC, EPA, DOT, DHS, USDA, FDA.
Effective Enforcement Targeting
Allegations
Allegations can be submitted by the trade directly through the e-Allegation (cbp.gov), a
Field Office, a Port of Entry or the designated CEE.
Within e-Allegations, the Report Trade Violations is to be used to report the following illegal trade activity: •Misclassification of imports •Country of Origin marking issues •Textile/Trade violations •IPR infringement •Export issues •Healthy and Safety Issues.
All allegations affecting a participating account are forwarded to the CEE.
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Way Forward
Expand number of Participating Accounts
Continue focus on: Streamlining entry summary and post entry summary processing Expediting cargo release Reducing paperwork
Expand bi-directional training CBP training for the AFT industry on key issues AFT industry training for CBP
PRECLASSIFICATION
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What Now? Apply to be part of the Centers of Excellence &
Expertise under the current Federal Register Notice
Contact:
Dora Murphy, Apparel, Footwear and Textiles Center Director San Francisco Field Office U.S. Customs and Border Protection [email protected] (415) 744-1530 x 233