We are going to get started with our webinar today. Thank you so much for joining us. Again, you are joining us for the Tariff Relief for DoD Contractors and Subs. We're going to be explaining DCMA Duty-Free and how those entries work. So we hope you are ready for lots of valuable information that will support you in those efforts. My name is Samantha Hurst. I will be your host today, and mostly just supporting here in the background. Should you have any technical difficulties or questions, you are welcome to reach out to me directly via the email that you received when you got confirmation of attending this webinar. So we're going to go over a few housekeeping items before we get started today. We can go to the next slide. For those of you that have joined us in the past, you will be well aware of how these typically go, but I'm sure we have many new faces, or attendees here. I can't see your faces, but many of you attending us, this webinar for the first time. So we have 45 minutes of content today with a Q&A section that will follow, and we do encourage that you drop your questions into the Q&A box that you should see on your settings panel, at any point during today's webinar, and we will do our best to get those answered either throughout or at the end during that session. One of the first questions that we always get, of course, is, "How do I receive the slides, the recording, and any other additional materials that might be provided?" We are going to make sure to take care of you. We do ask that you complete a quick feedback survey that will come via email from myself, and that typically will reach your inbox within no more than about 2 hours of today's event wrapping up. And don't worry if you don't receive that. We know some people's spam filters or, security filters do kind of block those, emails out, but we will get all of the material to anyone who attended today, within about 24 hours. Then finally, if you want to subscribe to get the invites, maybe you had someone in your organization who passed this invite along to you, this QR code or a link that we're about to drop into the chat will also get you the chance to subscribe and receive not only our event invites, but also our market updates. Onto our following slide here, we have just a quick disclaimer I want to explain. Again, if you've not attended one of these webinars, this is basically to explain to you all that we're not legal experts. None of our speakers, while they're very knowledgeable, they are not legal experts in this area. So we just ask that you understand this information is for educational purposes, and yes, to support your business, but not to be relied upon for legal or financial decisions. All right, now that that's out of the way, let's get to the important stuff of introducing our speakers. As I mentioned, we have a wealth of knowledge, as we always do on these events. Today, we have with us Lauren Holcomb, who's our Program Manager for Government Services, and Natalia Bailey, who's our Compliance Manager for Government Services. And before I hand it over to Lauren, I do want to tell you guys just a little bit about each of these individuals. So Lauren began her tenure with Expeditors about 17 years ago in Charlotte, working in our customs brokerage team there. After about eight years, she relocated to Atlanta, where she took on a regional role that eventually led to her furthering her concentration in compliance. She currently serves as our Program Manager for Government Services, as I mentioned, and is based in Dallas. In this capacity, she's responsible for overseeing regulatory and operational compliance for the government contracts. Now, as I mentioned, also with us is Natalia. She received a law degree, so while not necessarily a legal professional, is absolutely someone with a law background. She received that degree from Ural State Law Academy. She also has a dual BA in Political Science and International Studies. Now, she is based in Charleston, and interestingly, also joined Expeditors via our customs brokerage team, so a wealth of knowledge there and experience. In 2021, she earned her customs broker license and advanced into the role of District Trade Compliance and Employee Development Manager. Then last year, Natalia joined our government services team and quickly took ownership of our strategic compliance projects. So I'm going to turn this over to Lauren to get started with our content. Thank you all for joining. Thanks, Samantha, and thank you all for taking the time to join this webinar today. We hope you find it useful. We have a lot of content to cover on today's webinar, so we'll start with talking about the purpose of DCMA Duty-Free Entry. Then we'll look at the regulatory context surrounding it, give you an overview of the process and the roles and responsibilities within that process, and then we'll finish up by looking at the document requirements and some best practices. We'll also have time at the end, like Samantha mentioned, for Q&A. Before we move on, I just want to make a couple general notes about the content we are going to cover today. We are only covering the Duty-Free Entry process for the Department of Defense. Other agencies, like the Department of Energy or NASA, have their own Duty-Free Entry process and requirements, and we won't be covering those on this webinar. Also, we at Expeditors do not have a contract with the DoD for the procurement of goods or services, because that's not what we do. We provide services like transportation and customs brokerage, so our first-hand experience is only with acting as the customs broker in this process we're discussing. With that said, we expect the majority of the attendees will be prime or subcontractors that do hold DoD contracts for the procurement of goods or supplies. So we've done our best to include all the information available to us, on all aspects of the DCMA Duty-Free Entry process. And that brings me to our polling question. Samantha, will you please launch the polling question? Absolutely. Thank you. So for all of you, hopefully you can see this now, and we are just looking to kind of get an understanding of what your current level of interaction is with the DoD. You may be perhaps a prime contractor, a subcontractor, maybe both, or none. Perhaps you're just looking to have a better understanding of how this works, or you're interacting with a different government agency. We'll give it just a little bit longer. It looks like we have about 55% of you who have participated so far, so give it another 15 seconds or so. And just so you all know, this is, of course, anonymous. This information will not be shared with anyone else who's joining, in case anyone was concerned about that. We cannot see individual responses here, but I will end the poll here in just a second. It looks like, okay, we hit that 65% mark. That's what I was aiming for. Going to end the poll and share the results. So we do have quite a mix, it looks like. There you go, Lauren. Hopefully, you can see that. Okay, great. It looks like, yeah, we've got a good mix of both primes and subs, and then some acting, maybe with other government agencies are looking to get into DoD contracting. So I'll go ahead and get started. As many of you know, with the tariff increases over the past year, importers are looking for available opportunities to reduce those additional costs. For DoD contractors, the DCMA Duty-Free Entry has an established process and a feasible path towards major cost savings. Let's start with defining DCMA Duty-Free Entry. It allows certain goods imported under DoD contracts to enter the U.S. customs territory without paying customs duty. This exemption is governed by the Federal Acquisition Regulations, or FAR, and the Defense Federal Acquisition Regulation Supplement, DFARS. Done correctly, the DCMA DFE offers DoD contractors significant benefits. The most notable benefit, obviously, is contractors avoid having to pay import duties and fees. And that, in turn, allows them to offer more competitive pricing and helps to ensure timely delivery of mission-critical goods. So let's take a look at that DFARS that applies to this process. DFARS 252.225-7013 is the Duty-Free Entry clause. It was designed to prevent contractors and their suppliers from incurring unnecessary duties on goods purchased specifically for incorporation into end items delivered to the DoD. If defense contractors want to take advantage of Duty-Free Entry benefits, they would have to ensure that this clause is included in their contract. Within the clause, there are instructions for how to claim Duty-Free Entry. Contractors can also find the requirements for the shipping documents and customs forms. It also spells out what information should be provided to the contracting officer. And this is specifically where you can find the information you need to provide in that Duty-Free Entitlement request. And lastly, the clause also instructs on how to flow down the Duty-Free treatment to subcontractors or lower-tier subcontractors. I think it's important to stop here for a second and reiterate the fact that the DFARS clause, 252.225-7013, must be included in your contract in order to be eligible for this process. Another note worth mentioning, the DoD recently issued a memorandum that instructs contracting officers to include the Duty-Free Entry clause in all existing and future contracts, where Duty-Free Entry may be applicable. Now, let's review what materials might be eligible. So in order for the materials to be eligible, first, contractors need to ensure the duty was not included in the contract price for the items seeking Duty-Free Entry. Once that's confirmed, DFE can potentially apply to end items that are eligible products or qualifying end products. For the sake of time, we're not going to go into the definitions of qualifying country and qualifying country end product, but you can refer to DFARS clause 252.225-7013, the Buy American and Balance of Payments Program clause, and that's where you can find that information. Other products that might be eligible are components, including raw material and intermediate assemblies that were produced in those qualifying countries, and other supplies where the estimated duty will exceed $300 per shipment. That $300 threshold was determined to be the administrative cost with processing Duty-Free entries. So if the total duty amount is less than that, they've deemed it not worth the administrative cost. I also want to mention that questions about which materials are eligible under Duty-Free Entry should be directed to the Procuring Contracting Officer, also known as the PCO. The PCO is the contracting officer with the agency or department of the DoD that issued the contract. I'm only calling this out because there's also an Administrative Contracting Officer, or ACO, who's involved with processing these Duty-Free entries, and they may or may not be from the same agency that issued that contract. And I'll get into more detail on this in a later slide. The last note I have about eligibility is that the tariff application on imported material is determined by the U.S. Department of Commerce, Trade Enforcement, and U.S. Customs and Border Protection. So let's go into reviewing the applicable tariff for U.S. Customs. So just a quick recap of the information we just covered. Once you confirm that your contract contains the Duty-Free Entry clause, the cost of the duty for the DFE materials is not included in the contract, and the materials are deemed eligible based on the criteria we just reviewed. The next step will be notifying your customs broker that the goods should be entered under the HTS 9808.00.3000, which is applicable to articles for military departments and specifically military materials certified to the Commissioner of Customs by the authorized procuring agencies to be emergency war material purchased abroad. Some of you might be thinking, you know, "This is the catch. You know, I'm not importing emergency war materials, so unfortunately, this won't apply." Well, that's actually not the case, and it's understandable why this verbiage causes a lot of confusion among contractors. The reality is, when you have multiple agencies involved that don't work off the same sheet of music, there are imperfections, and in this case, the translation from the procurement law in the DFARS and the HTS, U.S. is imperfect. Even though the language of the HTS states emergency war material, the DFARS does not require an actual emergency and doesn't use the term war material. Keep in mind that the intent behind the regulatory DCMA DFE provisions is to reduce the government's contract liability, and for that reason, broad application of DFE certificates seems to currently be favored. Before I move on, it's worth noting that this classification only applies to articles for contracts with military departments, which are the Department of the Army, Department of the Navy, and the Department of the Air Force. Now, I'm going to introduce another agency that's involved in this process, which is DCMA. The Defense Contract Management Agency, or DCMA, is the Department of Defense component that helps administer DoD contracts. It works directly with defense suppliers to ensure that DoD, federal, and allied government supplies and services are delivered on time within the U.S. Customs territory. Within that DCMA structure, the transportation team, which is responsible for the management of the movement of materials for DoD contracts. And then further within that DCMA transportation team is a team, the DCMA Duty-Free Entry Team, and it's an extremely small team, only five or six people, and they are responsible for reviewing Duty-Free Entry certificates, which is roughly 30,000 a year, so they're extremely efficient. Now that we covered the agencies involved, we'll take a look at the entry requirements. For goods to be exempt from import duties, Duty-Free certification is required. The certification is provided directly by the DCMA Transportation Duty-Free Entry Team. If you are the importer, as long as you have an active defense contract when the goods are imported that contains the DFARS clause 252.225-7013, both prime contractors and any of their lower-tier subcontractors can be granted Duty-Free Entry. Also, please note that even though the DFE certificates are not required for the cargo release, they must be uploaded to the Customs ACE Document Imaging System, or referred to as DIS, within six months after the day of entry. After that certificate's uploaded into DIS, U.S. Customs will review it against the entry summary information for the goods that you're claiming the Duty-Free Entry status on. And if everything looks correct, Customs will liquidate the entry with no duties assessed against it. And we'll get into this in a future slide in more detail. Okay, so now we're going to move into the actual process for these entries, starting with the two different types. So it's important to point out that there's a significant difference between the DCMA Duty-Free Entry process consigned to commercial entities versus consigned to military installations. With shipments for commercial consignees, customs entry type 01, or consumption entry, must be filed, and the broker transmits the entry summary to customs electronically, just like most other entries today. But before the customs entry is filed, the prime contractor must submit a DFE entitlement request through the Procurement Integrated Enterprise Environment, which is typically goes by PIEE, P-I-E-E, where they also include the appropriate customs broker information. So in that entitlement request is a field to enter who your broker is, and then a specific email address that you want to be used for their notification. Once that entitlement request is approved by the contracting officer, the customs broker receives a tokenized email and follows the included link in that email to the DFE certificate module, where they submit the certificate request after the customs entry has already been cleared. So I know there's a lot of confusion around that, but after it's already been released is when that certificate needs to be created, because there's information from that customs entry that needs to be provided in that certificate request. After the DCMA DFE team approves and issues that certificate, they will notify the customs broker, who will need to upload that certificate to the customs DIS platform no later than six months after the entry. So taking a quick look at the military-consigned shipments, it's much different. In this case, the entry type is a 51, and there is no electronic submission from a broker to customs. The prime contractor also does not need to submit a Duty-Free Entitlement request in PIEE, and therefore, the broker also never receives the tokenized email and doesn't request a certificate. Instead, the broker submits the shipping documentation to the customs at the port of arrival, who then assigns a P99 entry number and releases the cargo. Please note here, too, that the procedures and document requirements vary based on the specific port. After the cargo is released, then Customs forwards all of that documentation that they received to the DCMA DFE team directly, and after that team reviews the documentation, they complete that 7501 form and issue the DFE certificate directly to Customs. As you can see, this process is still very manual, and for that reason, the best practice would be to notify your customs broker of that anticipated DCMA DFE shipment that's consigned to the military installation as soon as possible, to help avoid any unnecessary delays with that cargo. As a customs broker, we currently see far more DCMA DFE entries consigned to commercial entities, rather than the military, and for this reason, in the remainder of our webinar, we'll focus more on the process for those specifically commercial shipments. To get a better idea of how the DFE process works, let's take a look at the workflow diagram here. As you can see, there's multiple steps, and multiple participants are involved in these steps, but it all starts with the creation of that Duty-Free Entitlement by the prime contractor. If there is a lower-tier subcontractor, as I mentioned earlier, that can also take advantage of this, it would still need to be the prime contractor that is requesting that entitlement. After the entitlements are submitted, it goes to the reviewer, who, in this case, would either be an administrative or procuring contracting officer. They will review the entitlement and either approve it, deny it, or it could also be returned for corrections. If the DFE entitlement is approved, an automated tokenized email is sent from PIEE to the broker's email that you've listed in the entitlement. If no action is taken on that tokenized email, that link in that tokenized email, it will expire after 72 hours, and then will automatically re-trigger continuously for every 3 days for 30 days. If for some reason, that entry still doesn't need to be made past that 30 days, the prime contractor can go into that PIEE portal and re-trigger that email to the broker manually. Please also note that the contractor may submit multiple subcontract or purchase order- purchase orders on a single Duty-Free Entry entitlement request, because the entitlement requests are based on per foreign supplier. So I know, we get that question a lot, like, is it one entitlement per customs entry? And no, that's not the case, because it's based on the foreign supplier. From the workflow diagram that we just looked at, we know that DFE entitlement submitted by prime contractors can either be approved, returned, or denied. So what do these statuses mean? When the entitlement status is updated, it ultimately means that the entitlement request has been reviewed by the contracting officer. And then when the status changes to approved, it tells us that the contracting officer did not see any issues with the request. And once it goes into that approved status, like I said, that triggers the tokenized email to the customs broker. If the entitlement was returned, it means there's some issue with the request that prevented the contracting officer from approving it. In this case, the contractor is allowed to access that original request, make those appropriate modifications, and then resubmit it. The most common reasons for returned entitlements, as cited by DCMA, are the incorrect total contract dollar value, the incorrect contract expiration date, or the contract type. And then finally, the last status, if it's updated to denied, it signifies that the entitlement request had some fundamental issues that could not be fixed. If the entitlement request was denied, it typically means the contractor would have to go back in and create a new entitlement request. There could be various reasons for denials. For example, if it turns out that the contract does not contain that Duty-Free Entry clause. And in this case, the contractor can actually reach out to their contracting officer and request a contract modification before submitting another Duty-Free Entry entitlement request. Other reasons for denials are situations when the period of contract performance has already expired, incorrect contract delivery order was listed, or the PO number was erroneously listed in the contract number block, as well as incorrect CAGE codes used. And they'll also be denied if it's a duplicate request. Once the entitlement request is approved, assuming it eventually gets approved, the process for the customs broker begins Duty-Free Entry certificate. Following the access link provided in the tokenized email, the broker Duty-Free Entry certificate request in PIEE and submits it to the reviewer, which is the DCMA Duty-Free Entry team, the small team I referenced earlier. Upon their review, DCMA DFE team determines whether the certificate request should be approved, returned, or denied. If the certificate was approved, then the customs broker is notified automatically via that PIEE system in another email, and they are provided a link for accessing the DFE certificate. As I mentioned earlier, the broker must upload the Duty-Free Certificate to Customs ACE DIS platform within six months of the date of import for the entry to liquidate Duty-Free. An important note, as I mentioned earlier, the Duty-Free Entitlement is based on that foreign supplier. So if one import shipment contains goods from multiple foreign suppliers, then the broker would need to submit multiple Duty-Free Certificate requests for one customs entry. So again, in other words, it's, it's not one Duty-Free Certificate per customs entry. Now, we'll put it all together. Here's a view of the full process from the start of the entitlement request all the way through the Duty-Free Certificate issuance. So this shows you the handoff between the two requests is that automated email sent from PIEE to the broker. Okay, now that we've gone through the steps in the process, I will turn it over to Natalia, who will go through the different roles and responsibilities within this process. Thank you, Lauren. We will start with the prime contractor, which is the party who typically claims the Duty-Free Entry for eligible supplies that will be delivered under the contract. A necessary condition here is that the tariffs cannot be included in the contract price. In order to submit the Duty-Free Entry claim, the contractor would need to register as a vendor in the PIEE platform and follow the process for the entitlement request that we have just reviewed. Prime contractor is responsible for collecting and submitting all required information, documents, and customs forms in accordance with the DFARS Duty-Free Entry clause. Although customs broker is the party in charge Duty-Free Entry certificate in PIEE and submitting the approved certificate to the U.S. Customs and Border Protection, they have very limited functionality within PIEE and can only access it with a tokenized email, like was already mentioned before. They cannot search through the database of existing entitlements and approved certificates in PIEE. Next is contracting officer, and contracting officer is the first government reviewer in the Duty-Free Entry process. Within 20 days after they receive a notification of the submitted entitlement request, they review it against the contract, and it is the contracting officer who determines whether the performance of the contract requires the foreign supplies identified in the entitlement. Second level government reviewer is DCMA Transportation Duty-Free Entry Team. While they're not involved in entitlement request reviews and approvals, Duty-Free Entry certificate requests submitted by brokers for completeness and accuracy based on provided documentation. We will review documents required by DCMA in more detail on one of the next slides. Finally, U.S. Customs and Border Protection does not technically take part in the process of the Duty-Free Certificate approval, at least on the commercial side. However, they will review the certificate provided by the customs broker against the corresponding customs entry and liquidate the entry without duties or taxes as assessed against it, but only for goods covered by the certificate. Next slide, please. Thank you. We will now cover broker assignment in PIEE. Like I said, customs brokers have very limited functionality within the PIEE platform. The only way for a broker to access the certificate creation module is to follow the link provided in the tokenized email that they receive after the entitlement was approved. Duty-free entry dashboard, accessible to contractors, has external links to the CBP's customs broker search, which can help contractors find brokers' information for the entitlement or certificate. Note that multiple brokers can be added under the entitlement, and all of them will receive the tokenized email, if the entitlement gets successfully approved. Duty-free entry dashboard also allows, authorized users to add, remove, or update customs broker information. As a reminder, the token is valid for only 72 hours, and under the normal circumstances, tokenized emails will be automatically re-triggered every 3 days for the period of 30 days. However, there are other factors that might come into play. For Duty-Free Entry certificate request was initially returned, this might stop the token from generating and prevent the broker from gaining access to the certificate request module for making corrections. Please keep in mind that PIEE platform, in its current iteration, is still far from perfect. Unfortunately, it is not uncommon for it to time out prematurely, return errors, or create other issues that might require troubleshooting. These factors can significantly extend broker's processing time. But even if the period of 30 days has passed and the broker is not getting automated tokenized emails anymore, the process can be restarted as many times as needed, either by the prime contractor or by one of the government reviewers. Once the status of the Duty-Free Entry, entitlement, or certificate changes to completed, there is also a way for the authorized users to resend brokers emails. Here you can see the example of the tokenized email received by the customs broker. Note that it contains the PIEE access link, the entitlement number, which we did hide on the slide for confidentiality reasons, and a reminder that the PIEE access link will expire within the 72 hours. I will now talk about some general considerations that contractors should keep in mind when dealing with DCMA Duty-Free imports. Contractors do have certain reporting capabilities within the PIEE platform and can search through entitlements and certificates that were filed in the past. While the PIEE search tool has its own limitations, it can help locate specific entitlements or certificates, or at least narrow down the search to a specific contract number or date range. Of course, contractors can only see their own entitlements and certificates and are restricted from viewing forms submitted by other companies. Another thing to consider is situations when customs entries include product from more than one foreign supplier. Since each entitlement can only be filed for one specific foreign supplier, as Lauren already mentioned, it might be the case that there will be multiple entitlements and therefore certificates associated with a single customs entry. Another scenario involving multiple certificates per customs entry is when goods are imported under multiple active contracts. These scenarios have their own nuances and can significantly complicate processing, not only for the broker, but also for the DCMA reviewing team. We recommend that you take this into consideration and try to only include goods associated with a single contract and entitlement per entry, if possible. Timing is another important factor, and before goods are even imported to the United States, companies desiring to take advantage of the DCMA Duty-Free Entry provisions would have to ensure that there is an approved Duty-Free Entry entitlement, so that the certificate request process can start right away after the importation. Timing is also an essential, factor in the context of the certificate request and issuance, since U.S. Customs and Border Protection set the six-month timeframe for Duty-Free Certificates to be uploaded to their DIS system. Since the demand for these certificates is currently on the rise, as you can imagine, processing times might vary, and sometimes it takes a good couple of months for the certificates to be reviewed and approved by DCMA. If by the 6-month mark, the certificate was not provided to Customs, they will liquidate the entry with duties and fees assessed against it at a regular duty rate. Finally, to reiterate what was already mentioned earlier, only prime contractor can submit entitlements in PIEE, and if your company is a prime, you would have to create entitlements for your subcontractors. If your company is a sub, you must ensure that your prime provides you with a reliable and responsive point of contact to communicate over the Duty-Free Entry entitlement and or certificate creation. We will now review these two scenarios, the process from the standpoints of a prime contractor and a subcontractor in more detail. In this first scenario, it is the prime contractor who acts as an importer of record in the import transaction. This process is rather straightforward and follows the Duty-Free Entry workflow that Lauren covered earlier in this webinar. The contractor creates the entitlement in PIEE, listing their customs broker as the assigned broker. They would also advise their broker the entitlement number corresponding with a specific shipment. Once the entitlement is approved, the broker receives a PIEE token link to request the certificate. Customs broker then files an entry on behalf of the Duty-Free Entry certificate request in PIEE, and uploads it to the customs document imaging system, DIS, once the certificate is approved by DCMA. In the second scenario that you see here on the screen, it is the subcontractor who is acting as the importer of record and benefits from the Duty-Free Entry of goods. Please note that in this scenario, subcontractor does not have direct access to the PIEE platform. They would have to communicate with their prime regarding the Duty-Free Entitlement creation, their broker selection, and request token retriggers if needed. However, the subcontractor is still responsible for the customs entry filing, since they are the importer of record. It is important to understand that if something goes wrong during the DCMA Duty-Free Entry process and the certificate does not get approved timely, it is the subcontractor who will be on the hook for paying the duty in this scenario. If your company is both the subcontractor and the importer of record for DCMA Duty-Free entries, you would have to ensure that your communication with both your prime and your customs broker is streamlined, and that your broker has experience processing DCMA Duty-Free entries. All right, now we will review documentary requirements for the Duty-Free certification. These are the documents that your customs broker will be uploading into the PIEE platform as a part of the Duty-Free Certificate request. First of them is a commercial invoice. It is typically issued by the seller and serves as the evidence of the purchase. It should match the items covered on the Customs Form 7501. It is the DFARS requirement that commercial invoices for shipments covered under the Duty-Free Entry clause contain the prime contract number and, if applicable, the delivery order number. You would have to ensure that you communicate this requirement to your suppliers. While Customs Form 3461 is not technically required for the certificate request submission, it can also be uploaded to PIEE as long as it's accompanied by the entry summary Customs Form 7501. And similarly to a commercial invoice, 7501 must also list the DoD contract number and, if applicable, the delivery order number. It must also contain the Duty-Free Entry statement mentioned in the DFARS Duty-Free Entry clause. As a reminder, general customs requirements for entry documentation can be found in part 142.3 of customs regulations. Before we move on to the final segment of our webinar, we would like to add the Duty-Free Entry training, specifically as it pertains to the PIEE platform, can be found within the platform itself under the web-based training module. We have included the direct link to it on the bottom of the slide. If you have any additional questions regarding DCMA DFE process on the contractor side, you can also reach out to DCMA Duty-Free Entry team directly via the provided email. Now we would like to end our webinar with the overview of the best practices. We will start with prime contractors. First, before claiming goods under DCMA Duty-Free Entry provision, ensure that DFARS Duty-Free Entry clause is incorporated in your contract. If you do not find it there, you can reach out to your contracting officer and request a modification. Second, make sure you flow down this clause to your subcontractors so they can take advantage of the Duty-Free benefit as well. Next, build a trusted relationship with your contracting officer by engaging with them early and regularly. Not only they're a valuable information resource, they are also your first governmental reviewer in the Duty-Free Entry process. If you want your Duty-Free, entry, entitlement, or certificate to be approved without any issues, ensure that all information entered in the PIEE entitlement request form is accurate and does not contain typos or discrepancies. If you submit an entitlement request on behalf of your subcontractor, include the name of their customs broker, not your customs broker. Communicate the documentary and marking requirements to your suppliers to avoid processing delays, and use customs brokers' experience with DCMA Duty-Free entries to ensure that they have all necessary documents and Duty-Free Entry certificates. And lastly, invest in staff training and maintain robust record-keeping process. Now, let's review best practices for scenarios when your company is the supplier or subcontractor to the prime. First, check your purchase order and or agreement to make sure that the DFARS Duty-Free Entry clause was properly flown down to your company by the prime.... Of course, this will only work if the prime contract contains this clause in the first place. Share your broker's information with your prime to avoid confusion and tokens being sent to the wrong broker. Before importing goods into the U.S., confirm that the Duty-Free Entry entitlement was approved and that the tokenized email was sent to the broker. Stay in close communication with your broker to ensure that they have everything required for the certificate request submission, and assist them by acting as a liaison between them and your prime if any issues arise. Maintain a list of Duty-Free Entry entitlements, corresponding Duty-Free Entry certificates to avoid any miscommunication. Finally, monitor customs inquiries to ensure Duty-Free Entry certificates were received by your broker and uploaded to the customs DIS system. It is also recommended to retain copies for your records in case if you are ever asked to provide them by your prime contractor. This concludes our presentation. Thank you for your attention, and I will now turn it over to Samantha. Good. Natalia, thank you so much. Appreciate you continuing on with such valuable information. We're going to get to our question portion here in just a moment, as I know we have lots of good questions in the Q&A box. But for those of you who were curious, here is your certificate of completion. This webinar is providing continuing education credits for those of you who are needing those credits towards your licensed customs brokerage license or certifications. So you can take a screenshot of this, but also it will be re-provided to you as part of the slide deck that you will get with the rest of today's materials. So, Natalia and Lauren, we're gonna have you all come back on, and let's go through a few of the questions. We do have a lot of good ones. Looks like we've got about 20 that have now come through the Q&A, so no problem here getting all of these individuals started with asking questions. I always joke that this Q&A section is sort of like a middle school classroom. Nobody wants to raise their hands first, but you guys are doing a great job. You are all the honor students, obviously. Lauren or Natalia, any particular question you want to hit up first? Let's see. I know we had one... Oh, go ahead. I was gonna say, can DFE be used on shipments with commercial and government products? We get this question a lot. And the answer is yes. As long as the supplies purchased by the government are not identical in nature to the supplies sold to commercial customers, and it's feasible for the contractor to account for the differences in those supplies, then, you are able to, claim Duty-Free Entry on a shipment that contains both commercial and, government supplies. Okay, great. I'm sure that's definitely important to know, as I'm sure many, many shipments often probably contain materials for both. We had another question that came in related to, FTZs, I believe, and whether or not DCMA DFE can be claimed on those withdrawals. I can take this one. Yes, the answer is yes, it can be claimed, claimed for FTZ withdrawals. There are some nuances to it, of course, but it is possible. We don't see that many of these entries, but yeah. Absolutely something that came up. Great. Let's see. Trying to scroll through what we have. So another question: Can importers submit post summary corrections to request refunds on entries that were filed under this program? I can take this one as well. The answer is also yes, you can submit a post summary correction, but there are a few different scenarios that would have to be considered. I don't want to go into detail on each one of them. It's more of a, you know, one-on-one conversation with the customer at this point. But, what matters here is the timeliness of this process. You can see that there are a lot of different deadlines, and we have a very limited liquidation period for these entries. It's only six months, so we technically can submit post summary corrections before that timeline expires. There's an option of submitting a 514 protest after the liquidation, but customs advise that you can only do it within the 90-day time frame in order for entry to reliquidate. Good to know. We had another question, just, I guess, as a point of clarification on entitlement creation. This particular person commented... Goodness, sorry, my question just moved. This particular person commented that the entitlement can be requested and approved after importing goods, since you need the entry summary for the DFE entitlement request. I don't know if you all see that one, if, if, if I read that properly. The question is, if the entitlement request requires entry information? I think they're asking if we have, like, if we can clarify the timing of the entitlement creation, when that would occur. The entitlement creation should occur as soon as possible. As soon as that purchase order is placed with your supplier, that's when you should notify your contracting officer of that entitlement request. And I- Yeah, ideally, it would, it would happen, before, far before the actual import took place. Okay. Thank you. I think that helps to clarify that.... Great. This particular individual wants to know: If we're importing goods from a company in Europe, do we use our CAGE Code or theirs? So that refers back to whoever holds that contract. So it will be the CAGE code within that contract with the DoD that would be used for that, for that request. Okay, great. Staying on foreign suppliers, what if the foreign supplier ships two or more partials on a contract? Do they need to submit for DFE for each partial? No. You can include multiple partials, I guess, in one request as long as it's from the same foreign supplier. So those requests go based on the foreign supplier, and you can list all of the, you know, supplies and POs associated with that foreign supplier, and it doesn't necessarily have to be specific to one shipment. Let's see. This individual's typical duty is 3.5%, which is... Okay, I guess they were asking if we're going to discuss tariffs, because then they say, "Which are almost 50% of our cost." So I'm sorry, I'm not really clear now that I'm reading that out loud, the question, so if you can clarify your question, we'll come back around to it. The next one, what about LTSAs, where not all of the goods being imported may end up being consumed, by... There will be some leftover the supplier may want to sell to someone else. So they want the tariff exemption, but, yeah, cannot allow suppliers to just sell goods to someone else that were brought in under our DFE, I guess, is that, is that correct? Yes. Short answer, yes. Thank you. Let's see. Hey, Lauren, here's a question for you. What if I'm a flow-down subcontractor of a subcontractor, do I have to go to the prime contract, the prime contractor? If so, what PO is listed, the prime contractor's PO to the subcontractor or the subcontractor's PO to me? That's a good question. So typically, a lower-tier subcontractor will work with whoever their previous tier contractor is. So if it's, if you're the second tier, then you typically would work with your subcontractor, and they would hold a relationship with the prime. And in that case, you just have another party involved in communicating that. The PO is specific to the contract, the prime contract. So it would... unless, you know, the same PO carried through, it would be not your specific PO listed. Thank you. Next question: How realistic is it for a government contractor that doesn't have a dedicated inventory, for that matter, to take advantage of this remedy? How would we decide it, and would there be any requirements beside the certificate, such as inventory data? I can try to take this one. So, the goods would have to be identified specifically on the commercial invoice as the goods, imported under a specific contract, and, if there's no clear indication of this, you cannot claim, Duty-Free Entry treatment ultimately. So yeah, you have to show this in the documents. And, sorry, I missed the second part of this question. Yeah, and I think it's just important to reiterate the fact that the reason that they make you claim, either whether it's commercial or government, is just to make sure that the total amount that's being claimed under DFE doesn't exceed the total amount of the actual supplies within the government contract. So yeah, I think it's essential that you have some sort of way to keep track of that. I found the second part of the question here, too. How would we declare it, and would there be any other requirements besides the certificate, such as inventory data? Just like we already mentioned, you would have to indicate it, and you would have to submit the certificate request only for the parts that are in the entitlement. And that's basically the requirement. There are some certain documentary requirements and marking requirements, obviously, that we touched on today, and you can find more information on those in the DFARS Duty-Free Entry clause itself. Cool. Thank you, Natalia. Here's an interesting question: So what if the PCO does not do their part? Is the contractor then liable for the tariff charges? So they have 20 days from the time the request is submitted, the entitlement request is submitted, to review it. So, I don't know that it happens all that often, but ultimately, if that Duty-Free Certificate isn't issued and uploaded to DIS within six months of entry, then it's going to liquidate with duties. So whoever is acting as importer of record is responsible for those duties. Okay. Good point of clarification there, for sure. ... Lauren or Natalia, here's a question for you. If we have PIEE access, but we're not the prime on the contract, and we have the information for the contract, then can we file for DFE? So you can, in this, in the PIEE system, I believe you can actually physically do it. But according to the DCMA team, it is the prime contractor that is responsible for filing that entitlement request on behalf of their subcontractor. And I think that the issue may arise with the timing of it. So if you do request it and it is rejected because you are not the prime, then obviously it's just gonna take a little bit more time to get that entitlement approved. We have about 4 more minutes left, and so the voice that we did not introduce, Ted Lucas, has been helping us weed through questions. So, Ted, I appreciate that. With your expertise, working with our government services team, do you see any others that we really want to try to get to? And those of you that questions we are not able to get to in the next 4 minutes, don't worry, we will do our best to take those. We can pull a report and make sure that we go through and get back in touch with you all, to try to get those questions answered. Yeah, yeah, here's a- Ted, any you see that we should definitely hit? Yes. Can you claim Duty-Free Entry for shipments held in the U.S. in an FTZ or bonded warehouse? We already discussed the FTZ scenario, so it is possible. Bonded warehouse, we haven't seen any of this entry so far, but that would be a good question for the DCMA Duty-Free Entry team, for sure. Is there training on bringing RMA DoD units back to the United States? Not sure I'm familiar with this, but if you're specifically asking about training for DCMA Duty-Free Entry process, like we mentioned, that there are some training materials on the PIEE platform, itself, and they're pretty useful. Some of them are step-by-step walkthroughs. There are also additional tariffs that also oversee the Duty-Free applicability for different types of imports. Not every Duty-Free falls under the tariff we reviewed today. If it's a U.S. goods returned, you're gonna be looking at a different tariff and process for that. Just, it's specific to the scenario. Okay, a last, one question that I have here: Can we claim Duty-Free entries for goods already received, let's say, last year? If the goods have already been received, then that entry has already been filed without that Duty-Free Entitlement being approved, and then the certificate being created. So at that point, you're past that 60-day window to upload the Duty-Free Certificate into DIS. With that said, we know that there are different circumstances that take place. So I think it likely depends on your specific scenario, but yeah, it's the overall answer would be no, you can't claim Duty-Free Entry status at this point. Thank you for that. Again, we are right at time. We are not ignoring the fact we still have quite a few questions, but we want to be respectful of everybody's time on today's webinar, and the team will take these aside and go through them and make sure that we respond back to you directly. In our survey today, when you receive it, there is one question to ask if you would like a follow-up meeting with any of our speakers and/or other Expeditors contacts that can support you in these processes. Please let us know if you would, and then we will connect you with the team to make sure that we get any of your questions, or support that you might need taken care of. Again, thank you all so much for joining the webinar today. Lauren and Natalia, great job on all of the content. Thank you. These are some upcoming events that we'll show on the screen briefly here, that you can scan the QR codes and join us for our next topic. Thank you, everyone. Thank you.