Well, welcome to our webinar series that is hosted by the Expeditors family, and then from the customs brokerage team. Today, our session, it is really about breaking down the U.S. customs enforcement executive order. Why are we bringing topics for our dear audience today? That really is coming from the executive orders that was issued in the 3rd of June this year, on strengthening customs enforcements for the U.S. Customs. That brought about quite a lot of inquiries, and as the shippers and as active importers, we like to learn about what are some of the advice, what does that really means for our customers. Therefore, specially curated for our dear audience today, we are going to invite our guest speakers from the America, Vice President of Customs, as well as the Director of Customs Operation for America, Stephanie Holloway and Madeleine Veigel, to join our session today. Just a little bit of housekeeping before we kick off today's session. First and foremost, to hear the webinar, please click join audio at the bottom left of your Zoom window. We do have a Q&A sessions. In fact, you can also pose the questions that you may have alongside during the session. Simply just submit those questions in the Q&A box that you can find in the control panel at the bottom of this webinar. At the end of the session, yes, we would like for you to do a short survey for us upon completion, and then you will be guided through locations where you could download the slides. Finally, we do have several exciting webinar coming up, and so stay tuned with us by subscribing and checking out through the QR code over there. Today's session, I would like to reintroduce again. The next page, please, Gabby. Yes. We have Madeleine Veigel, she is the Vice President of Customs of America, and we have Stephanie Holloway, the Director of Customs Operations America. In the next few sessions, they will be giving us more details regarding the topic today. Thank you so much for joining us. I am Wang Ping, the Director of Account Managements for Expeditors. At the end of this session, my counterpart, Sonia, she will be helping to wrap up the session as well. On to Madeleine and Stephanie to take us away. Thank you, Wang Ping. Thank you. We are going to get started. Madeleine and I are also happy to take your questions. You can see the Q&A box, so if you have things that you're thinking of during this, by all means, you don't have to wait till the end. You can go ahead and type them into the box and we will maybe actually address them during the webinar or answer them as we continue on with the presentation. With that said, we always like to say that we're actually not lawyers. We are just customs brokers in the United States, and we are trying to get you the best information we have at the point that we have it. That's what this message helps describe. As Wang Ping said, this is all about what is happening with U.S. Customs right now. U.S. Customs is going through lots of changes, under the direction of the Trump administration, right? President Trump is making a lot of changes in the United States and importing is absolutely going to be impacted. It already has been, but they are really taking steps to formalize a lot of these changes. One thing that's a little bit interesting about the Trump administration is that they will tell you what they're going to do. We don't always have a lot of notice, but they do kind of lay out what their plans are. These four documents that are listed here are really important to understand if you're trying to really understand what the Trump administration is doing or where this is all going. We're going to touch specifically on the second one, the Executive Order 14411. But there has been a few other documents that have just come out in the last couple weeks that are very important. I just want to highlight them. So, of course, back when President Trump first took office in January 2025, one of the first documents he put out was this America First Trade Policy, and that really sets the stage for all of the things that have been happening as far as importing goes. So, there is a very strong desire by President Trump to have more items produced within the United States, and they are actively using tariffs to help support that goal. Okay? So then in June 3rd, there was an executive order came out that really directs U.S. Customs to take a number of actions. That is what this webinar is about. Okay? And then in the last couple weeks, there are some, I will say, kind of scary. This is not the same U.S. Customs from a year ago. This is, or two years ago. This is very different. There was a Trade Fraud Resource Guide that was published with our Department of Justice, so that is an area of our government that really lays out enforcement and what your expectations are if you are an importer into the United States, and really talks about what is expected of you. And then just a couple weeks ago, there was a report published, it was called The Great Trade Shipment Scam, but it really talks about really the belief of freight and goods that are moving through these supply chains, and maybe not an ethical way or not the correct way, that there is a lot of freight that is not being declared correctly, maybe not being labeled correctly. So it is very important to understand this piece, because that is where a lot of this is coming from. Okay? So there is a belief from the Trump administration that there is a lot of freight, like I said, moving between countries and maybe not being legally declared correctly or being labeled a different country or things like that. Okay? So I know a number of you on, some of you might be an importer into the United States, and this will all directly impact you. But even if you are not directly serving as importer of record, a lot of this will still impact you because whoever is serving as the importer of record is going to have a lot more questions for you. So think of it through that lens. Even if you are not the direct U.S. importer, this will trickle down. There will be impacts to manufacturers and shippers and lots of other parties in the supply chain. So let us first quickly look at what we are seeing right now in the United States as far as enforcement. So like I said, there has been different documents laid out, but some of them are pretty new. We are really starting to see the shift in U.S. Customs and what is happening, and we started seeing that last year. If you do not know, CF-28 and 29, those are kind of formal requests that are sent by U.S. Customs to a U.S. importer of record. You can see here in 2025, that number has jumped dramatically. There are lots and lots of questions being asked. Also, on the right-hand side, U.S. Customs actually publishes a lot of data statistics. I have one here that is linked. If you just Google, you will find a bunch of dashboards. Customs, through their own statistics, are telling us that they are doing less audits, but collecting more money. They are now collecting almost $800,000 per audit. Also, they are issuing a lot of penalties. They have already exceeded their fiscal year in this year. They have already collected $70 million in penalties, and that is well above what they collected last year, which was $46 million. There is a lot of activity. This is just a small portion that we are choosing to show here. Tied into this left-hand side here about document request, one thing that is really important, and I am not going to go through this in detail, but one thing that is really important to know is that when importers are getting requests from U.S. Customs now, they are very detailed requests. When they get sent these notices, it is not just a simple line like, "Please provide a certificate of origin." It is, "Show me the paper trail, show me the documents, help me understand how you came to this conclusion." Here is a very long one, right? Even if you are not the importer of record, whoever you sold to is going to come to you because they will need help understanding and gathering all of this information. This particular example is U.S. Customs saying, "I read the description and I am looking at the value, and those two are not making sense. So help me understand the product." But it is not just, "Hey, help me understand a little bit of the product." I need photographs. I need a written detailed description. I need where was it manufactured. I need product specification sheets, right? They need a whole lot of information. Also, for the value, right? How did you get there? Wire transfer records, bank payment, account numbers. These are very detailed information. These are things, like I said, that might end up on you even if you are not the importer of record into the United States. This is a good example. A CF-28 is when Customs is asking for questions. A CF-29 says that they are taking action. This one is a little bit interesting because the importer had received the CF-28, they had responded, and they had given, and you can actually see here in this top second paragraph, the importer had submitted manufacturing process, production records, factory overview, equipment records, workforce records. They had given a lot. But Customs looked, U.S. Customs had looked at all of that data together and they said, "This does not make sense." They are saying, "You are using machines that you bought after these goods were produced. The amount of employees you have does not make sense for how many items you are creating." They are looking very detailed to see if all of this story, it's not just can I find all the documents, it's does this document tell a full story? If they can't determine that that's true, the importer of record might be responsible, depending on what's happening, to pay additional duties or potentially additional penalties if needed or if determined. One other thing that I'll highlight is that U.S. Customs is working very closely with the Department of Justice. This is the people who run big lawyers for the government, and they haven't always traditionally worked very closely together. This is very different. Importers, as you can see here, and don't get hung up on the case, but Department of Justice and Customs are actively showing how much they're working together. They're actively showing, you can see here, I just gave two examples. Two came out in May, one came out in July. They have a very steady pace of cases that they're publicizing, and they are big amounts. You probably don't know this, but the FCA, that stands for the False Claims Act. They're using interesting ways to show that importers are not doing their job. But they're looking at, you can see in that bottom line, they're looking at things like country of origin. They're very interested in how freight is moving. That's going to be a common theme that we're looking at. Even without the executive order, because this big piece that we're talking about, this Executive Order 14411, I want to highlight that all of this has been happening for the last 18 months. We have a lot of momentum right now with U.S. Customs and everything they're moving to before we even start talking about the executive order. I'm going to hand this over to Madeleine now, and she's going to help break down what does this executive order have, and how should we understand it? Thank you so much, Stephanie, and hello, everybody. What you've heard so far from Stephanie is she went over the policy background in the beginning, highlighting those different documents that are making up the enforcement environment under the Trump administration. Then she also went over what is happening on the ground in the day-to-day world with the Customs Forms 28 and the Customs Forms 29, lots of requests and demands being made of importers. But now we will pivot to the actual executive order that came out on June 3rd from the administration. This, everybody, is a huge change here in the United States. I would say, well, first of all, it's not a very long document. It's only about five pages. If you are an importer in the United States, then I would highly encourage you to take a look at the document because it is not too long, and you will immediately see the direction that the Trump administration is going with this executive order, and how that sort of blends in with the other documents that Stephanie talked about at the very beginning here of the webinar. This is a big change because it shifts the right to import. I think anyone who is importing into the United States kind of believes they just have a right to import into the country. The executive order turns this into a privilege. Importing into the U.S. becomes more of a privilege, and you have to meet certain conditions in order to import or continue importing into the United States. We have broken out the executive order into five big areas, and that is what you see here. The first one being importer eligibility. There is a lot of additional information that Customs and the administration are going to require from companies importing into the United States. I will talk about that a little bit more in my next section as well. The administration also expects importers to remain in good standing. You have to be what is called in good standing, which means that you are a compliant importer, and you have paid all your duties and amounts due to the U.S. government in order to import into the U.S. There is that larger bucket of importer eligibility. The next big area is supply chain information. Now, this is something that has been evolving, meaning even the past or the previous administration, under the Biden administration, there was a heavy focus on forced labor. That trend, of course, continues under the Trump administration. That is goods that are manufactured with any forced or child or indentured labor. With that heightened area of focus, the government really began to scrutinize all entities in the supply chain, not just importer, consignee, shipper, but actual manufacturer of the goods and the manufacturer of those components that make up the goods. U.S. Customs, the administration, they want a lot more information about all the entities that are part of the supply chain, that go all the way back. This is a big theme of this executive order, obtaining more information about the product, the components of the product, and the entities involved in manufacturing and making those products. Then the third bucket is limited mitigation for penalties. Today, when you receive a penalty in the U.S., you have the option of mitigating that penalty to a lower amount, but you have to tell a good story. You have to explain to U.S. Customs and Border Protection the reason why you feel that the penalty should be mitigated to a lesser amount. Normally, that has to do with maybe it was a simple clerical error that caused the penalty. This is going to change with this executive order. You're not going to be able to mitigate as far down, or maybe you can't go quite as low as we've been used to going with mitigation requests. This is going to be a big change for penalties in general in the U.S. The fourth bucket is earlier risk identification. The government, again, not only wanting more information upstream in the supply chain, they are going to be vetting all parties within the supply chain. We don't yet know what that means, but it means vetting importers, it means vetting customs brokers, it means vetting other entities in the supply chain. The last bucket, which is very interesting, and which will affect many of you, are export records. This administration wants access to export records, which means the export declaration and possibly other documents that are filed at the time of export. I will talk about this a little bit more too in my next section. But these are really the big five areas that are really important and that are really the five big themes of the executive order. If we go to the next, yes. Another thing that's very important to know about the executive order is that it affects all parties throughout the supply chain. This is not just the importer of record. It also affects beneficial owners and affiliates of the companies, manufacturers and exporters, customs brokers, freight forwarders, custodians of bonded merchandise, meaning merchandise that is not released yet with U.S. Customs, and just all parties within the supply chain. This is really, really important. Why this executive order is so big is that it really affects all parties within the supply chain, and that's critical. It's not just customs declarations, everybody, and this is what's key. It is manifest data. Many of you affect, of course, with the information you provide, how the manifests are filed into the United States. It affects manifest data. It affects Importer Security Filing. I know many of you are involved in ensuring that the Importer Security Filing is filed with accurate and timely information. It also affects in-bonds or in-transit declarations. It's really up and down the whole supply chain and all the declarations that are filed with U.S. Customs. What we know and what we're still waiting on. We know the general direction, right? We've been going over that. We know what the general priorities are, but the timelines are kind of fuzzy, or what we call fuzzy, because in the executive order, it calls out that a few of the main buckets, such as the penalty mitigation guidelines, the export documentation, when you read the executive order, is supposed to be implemented this month in September. All the other items in the executive order, it looks like would be implemented the end of November. However, the way the executive order is worded is fuzzy, meaning oftentimes they say CBP, or Customs and Border Protection, will start or will initiate a certain area. That means that such as penalty mitigations, does not have to be fully implemented. It just means CBP, or Customs and Border Protection, has to take an initial step. They have to start the process. That's why we think that this implementation of the executive order will actually be something more between 12 and 18 months. But again, we really have to watch because we have to be ready for whatever comes out. But we do believe that a lot of this will go well beyond the end of November. We don't exactly know yet how Customs will implement this, and there's two ways that Customs normally does this in the United States. It's either through rulemaking, a notice of proposed rulemaking, or they can also implement what they call an interim final rule, which means the regulations are alive and well, and you can comment on them, but the changes will take place immediately, the comments will come after. The notice of proposed rulemaking, the first way is Customs solicits a whole bunch of comments, and then they issue the final regulations. We are hoping that that's the way that Customs will make these changes, many of the changes or the things that are talked about in the executive order, but we don't know that yet, which way they will go. We also don't have the procedures yet from U.S. Customs on how they're going to implement these changes, nor do we have the specific requirements. So that executive order, the problem with it right now is there's a lot of detail that is missing. A lot of detail missing. And that's what we're waiting upon. So there's still much more that will be coming, so you will hear much more from us as soon as we get and obtain more details from U.S. Customs. Okay. And then this is very important, and important for many of you who may be foreign importers of record in the United States. The term or the definition of foreign importer of record begins to change in terms of how the executive order looks at it. So today, and normally, how we've always looked at a foreign importer of record is a foreign company that has a Customs and Border Protection assigned importer number. So they're basically an entity without a U.S. tax ID. But with the executive order, that begins to shift because the executive order focuses more on who's responsible for the duties, right? Because U.S. Customs wants to make sure that those duties are paid. They want to make sure that the foreign company has sufficient U.S. assets in the United States, and we don't yet have the details on that. And they want information about the ownership of the company. Basically, they want to know, hey, does the company have enough resources to be able to pay all the duties? And is there a company that U.S. Customs can hold accountable if there are compliance issues? So more will come out of this, I'm sure, but it's a little bit of a shift on how the U.S. government is looking at foreign importers of record, because they consider them a risk because, again, they're worried that they don't have a party to go after if not all the duties are paid or there's some other type of compliance breach. Anyway. That gives you a summary of the executive order, and now I'm going to go into what this really means for importers, even for foreign importers of record, and for you who might just be exporters or manufacturers. Because again, as Stephanie mentioned also earlier in the webinar, you may be getting a lot more questions from the actual importer based on these changes. These are based on what importers can do right now and what they should be focused on based on the information that we have. Because remember, we do not have a lot of detail yet. As I mentioned earlier, the shift here with the executive order goes to importing becomes a privilege and not a right. Again, I said this change is so big. It is one of the biggest changes, I think, or in my opinion, the biggest change we have seen since 1993 when there was what is called the Mod Act, and that gave the responsibility, the administration at U.S. Customs put the responsibility of all the elements on a customs declaration to be the responsibility of the importer. The other big change that we have seen, which was very large, which my colleague Ted reminded us of on last week's webinar, is NAFTA. Of course, that agreement between Canada, the U.S., and Mexico, which is now USMCA, and which is also in a little bit, well, up in the air. But that was also a very big change. But this one is in that same realm. It is just as big. As I mentioned, Customs is looking for a lot more information about the company, the importer in the United States. The kind of information they are looking for is whether the company has, and that is also if you are a foreign importer of record, do you have sufficient and tangible domestic assets here in the United States? What is your anticipated import volume? When were you organized as an organization? The year. Who are the beneficial owners of the company? Who are the affiliates, business affiliates of the company? We do not know how Customs will want to collect that information, exactly what that information needs to look like in order for it to be sufficient, but it is a lot more information about the company itself. Also very important, and what I mentioned earlier, is the importer must be in good standing. The only definition we have of that is that they are a compliant importer and they have paid all of their customs liabilities, so they have nothing pending. No pending payment liabilities with U.S. Customs. That is also very important. As we learn more, of course, we will disseminate more information on that. Then there is going to be, as I mentioned, enhanced vetting of all parties, including importers and brokers. They have also said that a foreign importer of record will need to be C-TPAT, which is our supply chain security program, but there is also a compliance element to that piece to that. But the foreign importer would need to be C-TPAT, and if they are not, then they must work with a customs broker who is C-TPAT. But what we have asked importers to really look at in regards to some of these changes is see, hey, do you have any current unresolved compliance issues with U.S. Customs, or do you have any customs liabilities that you owe the government? This is something that you can already begin looking at as an importer to see, even a foreign importer, if you have any of this outstanding, just to take inventory at this point. Okay. Now, the next piece is something I think you may all be will get very involved in, and that's what I mentioned earlier about export records. The U.S. administration wants to see the export declaration that was filed at the country of export, along with possibly other documentation and other certification or certificates that may have been filed in order to export the goods to the United States. There are a whole bunch of questions about this. What exactly are the documents? At what point in time must those documents be provided to U.S. Customs? Who should be the party providing those documents to U.S. Customs, and how do we get those documents to U.S. Customs? Today in the U.S., U.S. Customs has a system called DIS, which is the Document Imaging System, and today we provide a lot of import documentation to U.S. Customs through that system. But we don't know if that will be the system for the export records or an entirely new system. We just don't know. Still lots of questions about this, but what we have told importers is begin to look at and begin to reach out to your exporters or overseas manufacturers, or to who is responsible for the export overseas. Is there a way for you to get at that documentation? That's something that you can look at already today is, do I have access to the export documentation? Or if you're the shipper manufacturer thinking, "Hey, how can I get this information to the importer?" This is something to at least think about at this point in time until we get more detail. Okay. Customs and Border Protection is also looking for proof earlier on and for more information earlier on in the supply chain. Again, they want more information about the companies and the entities. They're going to be vetting several parties within the supply chain. But what we also know is that they want to know about the imported goods supply chain and production methods, such as the manufacturer's product identification or identifier, like a model number, key specifications about the product. What are the components that make up that product, and where were those components obtained from? Customs also said they're going to be very focused on misclassification, so where someone misclassified a product, undervaluation, where they didn't value the product correctly, and illegal transshipment. Those are all areas that they're very focused on. Again, what we're telling our importers with all of this is look at the products that are most critical products that you're importing today into the United States, the most critical ones or maybe the most urgent ones, and can you trace the information all the way back to the origin? This is where you may have importers reaching back out to you, trying to obtain more information about where did the components that are in this product that I purchased from you, where were they obtained from? Who were the manufacturer of those components? Or maybe there will be more questions about the actual country of origin and how that was determined. We have told our importers, see if you can do that supply chain tracing on your most urgent or riskiest products that you bring into the United States. You may get a lot more questions from companies in the U.S. about additional information. Then lastly, penalties. As I mentioned, the penalty mitigation guidelines will be changing with U.S. Customs. Today, U.S. Customs has penalty mitigation guidelines that have been in place since the early 2000s. They are going to completely revamp those. There are really two. There are penalties in the U.S., and there is also what is called liquidated damages. Liquidated damages is when you breach the bond, really, that you have the security that you have on file with Customs. A penalty is more severe, where you have broken the law, and there may be gross negligence of some sort involved. It is more severe. Customs is revamping those mitigation guidelines, and they are saying that they are going to establish a floor of at least 50% of the assessed penalty. The penalty amounts oftentimes are very high because they are based on the value of the goods, or sometimes can be three times the value of the goods. If Customs is only going to mitigate that down about 50%, the penalty can be quite steep. Whereas today, especially with liquidated damages, you can reduce the amount of the penalty substantially if you provide a good explanation to U.S. Customs with the proper backup. The other important point here is that the revised standards are going to eliminate mitigation for repeat offenders. For those, if you have made this mistake more than once, you are not going to be able to mitigate that penalty. What is worrisome is we all know that even the very highly compliant importers, highly compliant transportation providers, highly compliant customs brokers, we can all make a mistake. We are hoping that Customs will reevaluate this and still provide some flexibility. But at this point, penalties can end up being something very, very costly. We have asked importers to really look at, for example, those document requests that Stephanie was talking about earlier. Have they received a bunch of those this year? Is there a theme? If there is a theme, have they been able to put the proper controls in place to mitigate that? Because you want to do as much as possible to avoid getting a penalty since these amounts or since the mitigation guidelines are changing. I must remind everybody that this is penalties, liquidated damages for everything. That includes manifests, so it is going to be really critical that all that information is super correct, Importer Security Filing, in bond transit declarations. Anyway, it affects all. It affects all the parties. Anyway, this is not very uplifting news, I apologize. But there is lots to think about and lots to get ready for with this executive order. I am going to pass it back to Stephanie. Stephanie, you are going to talk further about what we can do practically to prepare ourselves. We need a lot of preparation. We do need a lot of preparation. As Madeleine said, we have been trying at Expeditors to figure out ways to practically get ahead of this, and it is really hard without having a lot of information and those details from Customs. But one of the things, of course, that we're talking about is making sure that everybody knows this is happening, and share some practical things that some of our kind of best in class importers into the United States are doing. So one thing that's really important to know, we keep saying that this is all very important. But U.S. Customs just put out a bulletin maybe 10 days ago telling anybody who serves as an importer of record into the United States that they have to make sure that all of their information is updated. Okay? If you are the importer of record, and hopefully you know this, you have to make sure this information's updated. What they're looking to make sure is updated is your name, of course, your tax ID or the number that was assigned to you by U.S. Customs, your physical address, and it needs to be your physical address. It can't be your broker, it can't be an agent, it has to be the physical location. The mailing address. Oh, and your physical location can be outside of the United States. I'll just clarify that. Your mailing address, your email address, and your phone number. If you listen to everything that we've been talking about, of course, this is the first step that U.S. Customs is going to take because if you're going to enforce things, you need to make sure you have the right information on record. Like I said, if you are an importer of record, this is very important. This form that's kind of like your contact information, it's called the 5106, five one zero six. If you hear that number, that's what that is. You can Google U.S. Customs Form 5106 and you can see it. But this is what needs to be updated. So ideally, you can update this in your ACE Portal. So many of you that are U.S. importers have gotten an ACE Portal account because you wanted to get your IEEPA duty refunds, and this was one way to get those. Make sure that all the information is updated. I have a job aid that I'll also distribute, so if you need help looking at your account, how to do that, and then make sure that all the information is updated. Okay? This has to be done by September 18. If it is not done by September 18, Customs may void your importer number, and that is going to cause delays because then it needs to be reactivated, and we don't quite know what Customs is going to do when we ask them to reactivate importers because it is a very different U.S. Customs than what previous U.S. Customs was. Okay? So this is very important. One thing that's very tricky for me as a broker is I can't see this information anywhere. I can submit the information to Customs, but I can't get it back. So I don't know. I can see your mailing address, I can see your physical address, I can see your name. But I cannot see your phone number and I can't see your email. It is very hard for me to know which holds are out there or if you are at risk to have a hold. We have to all work together to make sure that we can get this information updated. This is very important. If you have contacts or a logistics team in the United States, it is worth sending them an email and just making sure that everything is updated. The other thing that is tricky, I will say one more thing on this. This was set up when you became an importer, so at that time, phone number and email may not have been collected. I think we probably have very big, good importers who might have holes in their data. This is very important for us to, like I said, all work together. What else can we do to help prepare? This is something that we have talked to U.S. importers. As we keep saying, even if you do not import into the U.S., this is still going to impact you. The first thing you need to make sure that you are doing if you are an importer is you have to make sure that you have a way to get the information from U.S. Customs. The best way is to make sure that you have a login to the ACE Portal. The ACE Portal is the online system that U.S. Customs loves to use. They will also mail CF- 28s or 29s, but you have a very short time to respond to them. You have 30 days for a CF -28 and 20 days for a CF -29. If it is going all over in the mail system, you might use up all of your time. Make sure that there is a named person who is checking in the ACE Portal. There is also a report that you can set up where you get noticed if you get sent a notice if U.S. Customs has sent something to your company. Then you need to try to understand it. I gave those examples early on, CF -28s, 29s. What is Customs asking for? Read between the lines. What are they testing? Then put your packet together, all of your information, and this is where maybe as a shipper you are going to have to provide information. You have to realize that the importer of records into the United States need this information very quickly. They have very short periods of time. Make sure that all the documents and everything you are submitting is telling a good story. U.S. Customs, I know, is using AI to help check. Does all of this tell a story, right? Are there any inconsistencies? It would be a good practice to make sure that it is telling a story. Of course, you reading it and putting it together, but understand that they are going to be using extra types of tools as well to help check it all. Then learn from this whole experience, right? How can you do this quicker? What could you have done differently? Just even knowing right now, where are all these documents at? How can you get to them? How can you put it all together? Then ideally, how can you test this before U.S. Customs comes and asks you for it? What can you do upstream right now before you have a very short period of time? All of this, like we keep saying, is so different than what we have done before in the United States. So we all have to figure out how to be very good citizens when it comes to importing if we all want to continue importing. Okay? Madeleine kind of alluded to this idea. Do not test everything. Do not get overwhelmed. I think sometimes we do that. We get overwhelmed, and then we do not know where to start. Okay? Take a deep breath and think about one product. Okay? Maybe choose your most popular product or the one that you make the most money on, or whatever it might be. Can you show who made it extensively, not just the top layer? Can you show where they all sourced from? Can you show where it came from? What supports it, right? What are all the documents that help tell that story? How do you connect all those pieces? Go look at that example of the CF -29 I gave, where they had given all those documents, but then they did not believe it told the whole story. Okay? From this, you can grade yourself. Are you green, yellow, red? Right? Are you complete? Does it do the whole thing? Do you have it but it is not telling the right story? Or are you missing pieces of the puzzle? Okay? How do you document what you have and then also test for the next product? Right? Really trying to understand, but do not do it all at one time. In English, we have a phrase, shovel the ocean. Just means you are trying to do too much. Just start with one product. You will learn so much just from that product. There is a really good use case that U.S. Customs has published. Now, it is specifically regarding forced labor. But I want you just to kind of put the specific topic aside, because in this guidance, U.S. Customs does a really good job laying out what they expect for a U.S. importer and how does somebody prove all of these things, right? It feels overwhelming. So how can you actually prove this? So, that is what this guide does. This guide, like I said, it is specifically for this one topic. But if you put that aside, you can actually see here when you look at these appendix, starting at Appendix B, supply chain due diligence, tracing and management, best practices for importers. Okay? Appendix C, best practice for submitting documents. Appendix D, isotopic testing. That is a specific way that you can try to show how a product comes to be and what types of components there are. It also has other types of things in here. But you can see here they give actual examples of how you could do this. So if you do not know where to start this document, even if you do not read it for slavery, you can really read it to understand supply chain diligence, tracing, and management, and what Customs is looking at, what U.S. Customs is looking for from you as an importer. Okay? What do you do with all of this information? What are the key takeaways? The first thing I think is genuinely scary, and I take this very seriously when I say it. We don't know what it's going to look like to be an importer into the U.S. As Madeleine said, most of us really have only ever experienced you being able to import into the United States, anybody being able to import into the United States in a, I wouldn't say easy way, but it's been accessible. We don't know what that's going to look like. We think that there's going to be maybe four buckets. There's going to be this concept of a foreign importer or a non-foreign importer. Remember, that's just not where you're headquartered. Madeleine touched on this. This is going to be what types of assets you have in the United States. How easy would it be for the U.S. government to try to recoup money per se, if they needed to get that from you? That's going to define whether or not you're foreign or not foreign. Then you're going to have good standing or not good standing. You could be a foreign importer in good standing. You could be a non-foreign importer in not good standing. There's going to be different configurations is what the executive order seems to say, but we don't know how that will be defined yet. We don't know. Somebody asked, "What does it look like to have enough assets?" We don't know yet. A lot of that's going to be coming out. The first thing, as Madeleine said, making sure you don't owe the U.S. government money is a great place to start. I think anyone who owes the U.S. government money is probably not going to be in good standing. Read, especially if you're an importer of record into the U.S., make sure you read this executive order. I know we all love using AI to help us read things, but this is really important. We referenced other documents here that are well worth your time to go look at them. They really are telling the story of what the U.S. government is doing and what direction they're moving in, and this is a big change. Absolutely big change. At the core of Customs is always these fundamentals of classification, valuation, origin, record keeping. Those are going to become more important than ever. Those all need to be very dialed in, and you need to be able to defend them. Beyond those are of course the fundamentals, how can you support and tell that whole story? How do you tell the story of how your price came to be, how your freight moved? Can you show that? Can you defend it? Can you speak to what is happening in your supply chain? There are very complex supply chains. This is more than any of us have ever been asked to do. I don't know how we're going to do it, but we will keep moving forward, of course, and figuring it out together. The big key part at the end here is, of course, don't wait. Madeleine said this. We can't all wait to have everything defined because then it will be too late. The thing that we can be doing now is to know our products, know what records we have available, know our supply chain, and how do we tell that story cohesively. Okay. I think with that said, that is the end of this. If you have more questions, go ahead and throw them into the chat. Madeleine, was there any kind of themes of questions that you wanted to highlight before we wrap up? Well, there was a good question someone asked about with the export documentation. When that gets submitted, is that going to be compared to the import declaration? Which I think is a great assumption that that's what- Yeah. -the government, the administration is probably looking to do. We don't know for certain, but it's probably a good assumption. What was declared at the time of export versus, "Hey, what do I see now on this import declaration?". Yeah. And that one's especially interesting because U.S. Customs just today put out a notice- Yeah. -where they're asking for feedback on- Feedback. -essentially what export docs are available. Yeah. There's many questions. But you can tell that they're trying to go deeper in understanding the export docs portion. Yeah. It was good to see everybody this notice today from Customs. It is about 20 pages. We have not had a chance to read it yet, at least I have not. It is good that they are asking for feedback from the trade. Yeah. This is an opportunity to tell Customs, "Hey, I can provide this type of information, but I cannot provide this." Anyway, it is good that they are asking for this feedback, and hopefully lots of people in the trade will provide that feedback. Yeah, especially around one other thing that is really intriguing about export declarations is, the U.S. ourselves does not allow our export declarations to be given. Right. Right? Am I saying that correctly? That's right. Yeah. Yeah. So really ironic- We're not allowed to share. I know. -situation here. I think there's other countries who probably have similar regulations- Yeah. -or things like that. We also have, in the U.S., between the U.S. and Canada, there's not always an export declaration done. So there's also going to be situations where they're just not available. So the export declaration one, it causes a lot of chaos, I think- Yeah. -in many of our brains. But we don't have any answers. I think, Madeleine, do you remember the date that the comments need to be submitted by? I think it's actually a ways out, like December 1st, if I'm not mistaken. That's what I thought, yeah. Yeah. It's in December. It's a lot of time. I think that pretty much says that we probably maybe won't see something active on it. Right. I mean- That's what I'm thinking. -can't rule out anything, but that's what that's pointing to, is that we probably won't see big, meaningful export changes until at least after that comment period. Yeah. Okay. I think that we can wrap up here. Sonia, did you want to come on? Yeah. Lots of people want the prezo, so- Yes. Yes help them out. Can they get the prezo? Can they get the recording? They can. Thank you very much, Stephanie and Madeleine. We hope the session provided useful information and clarity around all of these changes. You absolutely can get access to the materials. What you need to do, though, is complete the post-event survey that we send out, and then once you do that, all these materials will be made available to you. Just a quick recap on today. Stephanie and Madeleine, thank you so much for coming during your evening on an Asia-friendly time zone. We really appreciate it. We focused today especially on the Executive Order 14411. This is all about strengthening the customs enforcement and introducing new standards for foreign importers. What we are seeing is the increased customs scrutiny, more penalties, we discussed that, along with these audits, and now requiring much more detailed information than previously. As a result, even if you are not that direct importer, you may be obliged and involved with having to provide a lot more thorough information. Be ready to help out there. A quick reminder, to get your importer records updated by September 18th, and that is in that Form 5106 that was mentioned. Lastly, Stephanie, it was your great tip around the product exercise. Go through the process on one of your prominent products and see if you can test and prove the product information that customs would need. With that, I would like to thank our speakers, and I would like to thank all of our customers for joining today, and taking out some of your valuable time to participate in the webinar. I wish you a great day ahead. Thanks, everyone. Thank you, everybody. Thank you. Have a great day, everybody. Thank you. Bye.
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