• By the end of August Treasury anticipates proposing a rule pertaining to prior disclosures and related procedures for demanding the payment of duties, taxes or other revenue for violations of 19 USC 1592 or 1593a when a penalty claim is not issued.  These changes  are designed to encourage participation in the prior disclosure program and enhance the effectiveness of the duty/revenue demand process. 

• A Final Rule concerning the elimination of most paper Courtesy Notices of Liquidation is expected to be published no later than September.

• By the end of September a Final Rule relating to customs broker's recordkeeping requirements will be issued by September.  Anticipated changes include; (1) permitting licensed brokers to store business records relating to imports at any U.S. location as long as the designated recordkeeping custodian makes all records available to CBP within a reasonable time frame at the broker district that covers the CBP port to which the records relate and, (2) removing the requirement that brokers retain certain entry records in their original format for 120 days after the release or conditional release of imported goods.

• An advanced notice of proposed rulemaking soliciting comments on various issues related to the labeling and advertising of alcohol beverages that contain caffeine, vitamins and minerals is scheduled for December.  Also expected by the end of December is an notice of proposed rulemaking requesting public input on a petition to require; (1) the use of 100% U.S. - grown grapes in wines labeled with American appellations of origin and, (2) the labeling of all countries of origin if grapes from multiple countries are used to produce the wine.

The world continues to be an interesting place for those of us involved in global supply chain security.  Global supply chain professionals (as well as our internal and external partners) must be aware of political and security issues in every corner of the world in order to be good stewards of our company's people and assets.  In recognition of this reality, Customs & Border Protection (CBP) has recently announced its intention to evaluate the most active and innovative of its C-TPAT members (those in the coveted Tier 3) based on their ability to accurately 'map' their supply chains.  While the methodologies surrounding supply chain mapping are familiar to most security experts, they may not be to those teams in your company who are responsible for maintaining your good reputation with CBP.  The requirements for supply chain mapping include the need to clearly detail each individual trade lane, identify potential risks, evaluate the vulnerabilities, design and implement tactics to mitigate the vulnerabilities, document, and then repeat.  It may surprise you to find out that most companies do not have anywhere near this kind of detailed operational knowledge of their international supply chains.

An effective security program will be the driver for positive change within a company's supply chain strategy.  Not only will it be the force behind illuminating the details of a trade lane, it will also provide valuable insight in to regional political environments and security situations that can affect supply chain operations.  An example of this insight can be found in the recent unrest in China.  The implications of this seemingly 'political' issue directly affect the security posture of most importers.  It is undeniable that the economy in China continues to overheat.  The result has been increasing demands for western-style labor reforms by the workers who are responsible for the effective operation of the 'workshop of the world'.  In fact more than 50 workers in a plant that supplies critical components to Honda have been clashing with police on a regular basis as part of their 'work stoppage'.