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Apparel, Footwear and Textile Center of Excellence and Expertise

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Goals of Centers 1.  Facilitate legitimate trade through effective risk segmentation

-  Utilize account based methods to process trade -  Expand partnerships - move more importers to trusted trader status -  Develop and implement comprehensive strategies to manage risk

2.  Increase industry-based knowledge within CBP -  Advance bi-directional education to raise industry knowledge -  Engage industry groups and key stakeholders -  Bring all of CBP’s expertise to bear on a single industry in a virtual

environment

3.  Enhance enforcement and address industry risks -  Leverage industry to identify issues of mutual interest to provide CBP with

targeting, enforcement, and/or intelligence information – Trade Intelligence -  Coordinate enforcement efforts by industry to address unique risks

Projected End State Procedures

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  Cargo release/Admissibility

  Inbond

  Warehouse entries

  Bonded warehouses

  Submit necessary documentation for release

  Adhere to current regulations

  ALL processes will remain at the ports

  Drawback Center

  NO CHANGE TO EXSITING SHIPPING PATTERNS

Port of Entry Centers of Excellence and Expertise   Entry Summaries (ACS/ACE)

  EIP/RLF

  Rejections/Cancellation

  Census Warnings

  CBP 28 and 29

  AD/CV

  Revenue Collection

  Reconciliation

  FTZ

  Quota Entries

  Post-Summary Corrections

  Post-Entry Amendments

  Internal Advice

  Protests/Petitions

  Prior Disclosures

  Temporary Importations under Bond (TIB)

  Liquidation

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Benefits of Centers

Action Benefits Eliminates unnecessary duplicative work from compliant imports

• Fewer cargo delays • Reduced costs • Greater predictability

Ports of Entry focus shifts to high-risk shipments

• More complex enforcement work • Improved enforcement results: o Increased import safety o Increased revenue protection o Reduced economic loss to IPR theft

Centralized office for trade 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

Cross-functional expertise • Environment for in-depth learning to increase CBP expertise and therefore enforcement

San Francisco Apparel,

Footwear & Textiles

Los Angeles Electronics

Laredo Machinery

Current 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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Year Center

FY 2012

•  Pharmaceuticals, Health & Chemicals •  Electronics •  Automotive & Aerospace •  Petroleum, Natural Gas & Minerals

April 2013

•  Base Metals •  Industrial & Manufacturing Materials •  Machinery

June 2013

•  Agriculture & Prepared Products •  Apparel, Footwear & Textiles •  Consumer Products & Mass Merchandising

Center Schedule Opening Dates

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Apparel, Footwear and Textile Center of Excellence and Expertise Organizational Chart

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DIRECTOR DORA MURPHY

Enforcement Branch

Validation & Compliance Branch

Partnership Branch

LSS integration into the CEE   Many trade issues addressed by the Centers are scientific or engineer

related.

  Laboratories and Scientific Services (LSS) will integrate into the Centers to provide a uniformed approach to facilitation and enforcement.

  Each CEE will be assigned a primary and alternate LSS Center Technical Advisors (CTA).

  CTAs will remain under the LSS organization structure, but directly assist the CEEs on a variety of issues: C/O determinations, Classification opinions, IPR determinations, Exclusion Orders, etc.

  Primary CTA for the AFT CEE will be the Lab Director from San Francisco.

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Apparel,  Footwear  &  Tex0le  Center  of  Excellence  &  Exper0se  

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  Interna0onal  Trade  Specialists  Opera0on  Specialists  Senior  Import  Specialists  

Import  Specialist  Supervisory  Import  Specialists  Supervisory  Interna0onal  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  

Na0onal  Account  Managers    

Matrix  Members:      Import  Specialists  Senior  Import  Specialists  Supervisory  Import  Specialists  Na0onal  Import  Specialist  Asst.  

Na0onal  Import  Specialist    

Branch Chief

Laboratories and Scientific Services Primary Center Technical Advisor

Alternate Center Technical Advisors HQ Science Officer

Branch Chief

PARTNERSHIP

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AFT Center Partnership Branch Goals

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Ensure Uniformity Create Efficiencies

Reduce Redundancies Enhance Industry Expertise

Facilitate Trade

Ensure Uniformity Create Efficiencies

Reduce Redundancies Enhance Industry Expertise

Facilitate Trade

AFT Center Partnership Branch

 The AFT CEE Partnership Branch is comprised of:

  Entry Specialists   Supervisory Entry Specialists   Import Specialists   Senior Import Specialists   Supervisory Import Specialists   National Account Managers   National Import Specialists   National Import Specialist Assistants

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AFT Center Partnership Branch, Cont.

  The Partnership Branch currently contains Core and Matrix members located nationwide.

  The AFT Center Director has direct oversight of the Partnership Branch. The Assistant Director, Partnership, and Branch Chiefs oversee day-to-day operations.

  The Partnership Branch is organized by Account. Currently there are eight Participating Accounts.

  To better ensure uniformity, processing of the participating account’s entry summaries and post entry summary activity is performed by Partnership employees assigned to the account.

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Cargo Release

The AFT Center Partnership Branch

  runs cargo hold reports

  works with ports of entry to resolve holds and expedite release

  monitors cargo exams and exam time frames

  works with ports of entry to expedite exams

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Entry and Post Entry Summary Processing

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The Partnership Branch performs certain entry and post entry summary functions for participating accounts and

works to ensure uniformity and create efficiencies.

38,509 entry summaries with a total value of $3,121,444,805 have been filed for participating accounts as of the AFT

Center’s operational date of 07/10/13.

Centers of Excellence and Expertise Test Guidelines: Responsibilities and Procedures for Participating Accounts and Their Brokers, Agents, or Filers is posted on CBP.gov.

These guidelines are updated periodically.

Post Entry Summary Processing

  For participating accounts, certain entries filed prior to and after the implementation date of the AFT Center can be submitted to the Center for Post Summary processing.

  Post entry summary processing includes protests and petitions, post entry amendments, post summary corrections and cancellation requests.

  Reconciliation entries should currently be filed at the assigned port of entry and drawback claims should be filed at one of the four existing Drawback centers.

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Achievements

  Resolved holds

  Expedited cargo release

  Reduced number of CBP Form 28s issued

  Reduced number of samples requested

  Reduced number of documents provided to CBP

  Expanded training within CBP for Apparel, Footwear and Textile importations

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Way Forward

  Expand number of Participating Accounts

  Establish Pre-Classification Program

  Continue focus on:   Streamlining entry summary and post entry summary processing   Expediting cargo release   Reducing paperwork

  Initiate bi-directional training   CBP training for the AFT industry on key issues   AFT industry training for CBP

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Pre-Classification Program

  The Partnership Branch is working on creating a Pre-Classification program for Apparel, Footwear, and Textiles.

  Pre-classification will be a program to provide importers with classification advice prior to importation and entry.

  The Pre-Classification option is intended for participating accounts and will be conducted in the AFT Center’s virtual environment.

  The Partnership Branch welcomes feedback and input from the AFT industry on its implementation.

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ENFORCEMENT

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Apparel, Footwear and Textiles Import Highlights

  $131.6 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 ($58.5 billion)   Vietnam ($9.6 billion)   India ($6.5 billion)   Indonesia 4 ($6.2 billion)   Mexico ($5.8 billion)

  Over 64,800 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)

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Apparel, Footwear and Textiles vs. All Imports

FY12 Industry Total All Imports % OverallImporters 64.9K 307.8K 21%Lines 15.2M 123.7M 12%Value $132.8B $2.4T 6%Duty $14.0B $30.0B 47%

Textiles CEE FY2010 FY2011 FY2012

%CHG FY11-12

Importers 64.5K 64.2K 64.9K 1%Lines 12.4M 13.5M 15.2M 13%Value $117.7B $133.0B $132.8B 0%Duty $12.3B $14.1B $14.0B 0%

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Enforcement   Focus on areas of risk

1.  Intellectual Property Rights   59% of all FY 12 IPR seizures   Undermine domestic producers

2.  Trade Agreements   14% of imported value claims preferential treatment   False preferential claims undermine trade agreements

3.  Revenue   Duty collected by CBP on textile and apparel goods still accounts for

more than 40% of all duties   Misclassification and undervaluation are schemes to evade high duty

rates on textiles and footwear

AFT CEE Enforcement

 Enforcement activity can take place at time of entry or at post-release.

  Some main areas of focus include, but are not limited to the following:   Intellectual Property  Free Trade Agreements  Revenue evasion  Transshipment

 Enforcement actions involving participating accounts will be coordinated with the Center prior to issuance.

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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 to be forwarded to the CEE.

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AFT CEE Operations  The goal of our operations is to identify specific violators and

take appropriate action without negatively impacting the entire textile/wearing apparel/footwear industry.

  In addition, our operations will focus on protecting our participating accounts from illegal importing/exporting of their products.

 The AFT CEE will work with the participating accounts to establish concepts/plans for future operations.

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Special Operation

 Joint operation by:   AFT-CEE  PORT OF ENTRY

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Operation Results

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•  Four Day Operation

•  Total Intellectual Property Rights Seizures: 147

•  Total Manfr’s Suggested Retail Price: $1,132,414

•  Total Domestic Value: $385,305

IPR Recordation   The AFT CEE recommendations all Intellectual Property is recorded with

CBP.

  CBP can provide a webinar on How to Record IPR 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 CEE Enforcement Branch  The AFT CEE Enforcement Branch is comprised of Import

Specialists, Supervisory Import Specialists, International Trade Specialists, Supervisory International Trade Specialists, Trade Program Managers, Operations Specialists, Asst. Port Directors, Auditors, Supply Chain Security Specialists, and Field Analysis Specialists.

 The Enforcement Branch currently contains Core and Matrix members.

 The AFT Director has direct oversight of the Enforcement Branch as the Asst. Director and Enforcement Branch Chief conduct day to day operations.

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COMPLIANCE &

VALIDATION (coming soon)

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What Now?   Apply to be part of the Apparel, Footwear & Textile

Center under the current Federal Register Notice

  Contact:

Dora Murphy Assistant Director, Field Operations, Trade Apparel, Footwear and Textiles Center Director San Francisco Field Office U.S. Customs and Border Protection Dora.Murphy@cbp.dhs.gov (415) 744-1530 x 233

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