Apparel, Footwear and Textile Center of Excellence and

Apparel, Footwear and Textile
Center of Excellence and Expertise
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Goals of Centers
1.  Facilitate legitimate trade through effective risk segmentation
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Utilize account based methods to process trade
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Expand partnerships - move more importers to trusted trader status
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Develop and implement comprehensive strategies to manage risk
2.  Increase industry-based knowledge within CBP
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Advance bi-directional education to raise industry knowledge
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Engage industry groups and key stakeholders
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Bring all of CBP’s expertise to bear on a single industry in a virtual
environment
3.  Enhance enforcement and address industry risks
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Leverage industry to identify issues of mutual interest to provide CBP with
targeting, enforcement, and/or intelligence information – Trade Intelligence
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Coordinate enforcement efforts by industry to address unique risks
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Projected End State Procedures
Port of Entry
Centers of Excellence and
Expertise
  Entry Summaries (ACS/ACE)
  Cargo release/Admissibility
  Inbond
  Warehouse entries
  Bonded warehouses
  Submit necessary documentation for release
  Adhere to current regulations
  ALL processes will remain at the ports
  Drawback Center
  EIP/RLF
  Rejections/Cancellation
  Census Warnings
  CBP 28 and 29
  AD/CV
  Revenue Collection
  Reconciliation
  FTZ
  Quota Entries
  NO CHANGE TO EXSITING SHIPPING
PATTERNS
  Post-Summary Corrections
  Post-Entry Amendments
  Internal Advice
  Protests/Petitions
  Prior Disclosures
  Temporary Importations under Bond (TIB)
  Liquidation
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Benefits of Centers
Action
Eliminates unnecessary
duplicative work from
compliant imports
Ports of Entry focus shifts
to high-risk shipments
Centralized office for trade
inquiries
Cross-functional expertise
Benefits
• Fewer cargo delays
• Reduced costs
• Greater predictability
• More complex enforcement work
• Improved enforcement results:
o Increased import safety
o Increased revenue protection
o Reduced economic loss to IPR theft
• Improved relationship with CBP as
small/medium-sized importers have a
streamlined inquiry process for
resolving concerns
• Increased uniformity and
transparency for the trade
• Environment for in-depth learning to
increase CBP expertise and
therefore enforcement
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Current Centers of Excellence and Expertise
Buffalo
Industrial &
Manufacturing
Materials
Chicago
Base Metals
Detroit
Automotive &
Aerospace
San Francisco
Apparel,
Footwear &
Textiles
New York
Pharmaceuticals,
Health &
Chemicals
Atlanta
Consumer
Products &
Mass
Merchandising
Los Angeles
Electronics
Laredo
Machinery
Houston
Petroleum,
Natural Gas &
Minerals
Miami
Agriculture &
Prepared
Products
Center Schedule Opening Dates
Year
FY 2012
Center
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• 
• 
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Pharmaceuticals, Health & Chemicals
Electronics
Automotive & Aerospace
Petroleum, Natural Gas & Minerals
April
2013
•  Base Metals
•  Industrial & Manufacturing Materials
•  Machinery
June
2013
•  Agriculture & Prepared Products
•  Apparel, Footwear & Textiles
•  Consumer Products & Mass Merchandising
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Apparel, Footwear and Textile
Center of Excellence and Expertise
Organizational Chart
DIRECTOR
DORA MURPHY
Partnership
Branch
Enforcement
Branch
Validation &
Compliance
Branch
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LSS integration into the CEE
  Many trade issues addressed by the Centers are scientific or engineer
related.
  Laboratories and Scientific Services (LSS) will integrate into the
Centers to provide a uniformed approach to facilitation and
enforcement.
  Each CEE will be assigned a primary and alternate LSS Center
Technical Advisors (CTA).
  CTAs will remain under the LSS organization structure, but directly
assist the CEEs on a variety of issues: C/O determinations,
Classification opinions, IPR determinations, Exclusion Orders, etc.
  Primary CTA for the AFT CEE will be the Lab Director from San
Francisco.
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Apparel, Footwear & Tex0le Center of Excellence & Exper0se CEE Director
Dora Murphy
Laboratories and Scientific Services
Primary Center Technical Advisor
Alternate Center Technical Advisors
HQ Science Officer
Deputy Director
Vacant
Assistant Director
Validation & Compliance
Assistant Director
Enforcement
Vacant
Assistant Director
Partnership
Branch Chief
Vacant
Branch Chief
Branch Chief
Branch Chief
Matrix Members: Core Members: Import Specialist Senior Import Specialists Program Manager Asst. Port Director Interna0onal Trade Specialists Opera0on Specialists Senior Import Specialists Import Specialist Supervisory Import Specialists Supervisory Interna0onal Trade Specialist Auditor Field Analysis Specialist Supply Chain Security Specialists Core Members: Import Specialists Senior Import Specialists Entry Specialists Supervisory Entry Specialist Na0onal Account Managers Matrix Members: Import Specialists Senior Import Specialists Supervisory Import Specialists Na0onal Import Specialist Asst. Na0onal Import Specialist PARTNERSHIP
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AFT Center Partnership Branch Goals
Ensure Uniformity
Create Efficiencies
Reduce Redundancies
Enhance Industry Expertise
Facilitate Trade
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AFT Center Partnership Branch
  The AFT CEE Partnership Branch is comprised of:
  Entry Specialists
  Supervisory Entry Specialists
  Import Specialists
  Senior Import Specialists
  Supervisory Import Specialists
  National Account Managers
  National Import Specialists
  National Import Specialist Assistants
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AFT Center Partnership Branch, Cont.
  The Partnership Branch currently contains Core and Matrix
members located nationwide.
  The AFT Center Director has direct oversight of the
Partnership Branch. The Assistant Director, Partnership, and
Branch Chiefs oversee day-to-day operations.
  The Partnership Branch is organized by Account. Currently
there are eight Participating Accounts.
  To better ensure uniformity, processing of the participating
account’s entry summaries and post entry summary activity is
performed by Partnership employees assigned to the account.
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Cargo Release
The AFT Center Partnership Branch
  runs cargo hold reports
  works with ports of entry to resolve holds and expedite release
  monitors cargo exams and exam time frames
  works with ports of entry to expedite exams
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Entry and Post Entry Summary Processing
The Partnership Branch performs certain entry and post
entry summary functions for participating accounts and
works to ensure uniformity and create efficiencies.
38,509 entry summaries with a total value of $3,121,444,805
have been filed for participating accounts as of the AFT
Center’s operational date of 07/10/13.
Centers of Excellence and Expertise Test Guidelines:
Responsibilities and Procedures for Participating Accounts
and Their Brokers, Agents, or Filers is posted on CBP.gov.
These guidelines are updated periodically.
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Post Entry Summary Processing
  For participating accounts, certain entries filed prior to and
after the implementation date of the AFT Center can be
submitted to the Center for Post Summary processing.
  Post entry summary processing includes protests and
petitions, post entry amendments, post summary corrections
and cancellation requests.
  Reconciliation entries should currently be filed at the assigned
port of entry and drawback claims should be filed at one of the
four existing Drawback centers.
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Achievements
  Resolved holds
  Expedited cargo release
  Reduced number of CBP Form 28s issued
  Reduced number of samples requested
  Reduced number of documents provided to CBP
  Expanded training within CBP for Apparel, Footwear and
Textile importations
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Way Forward
  Expand number of Participating Accounts
  Establish Pre-Classification Program
  Continue focus on:
  Streamlining entry summary and post entry summary processing
  Expediting cargo release
  Reducing paperwork
  Initiate bi-directional training
  CBP training for the AFT industry on key issues
  AFT industry training for CBP
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Pre-Classification Program
  The Partnership Branch is working on creating a PreClassification program for Apparel, Footwear, and Textiles.
  Pre-classification will be a program to provide importers with
classification advice prior to importation and entry.
  The Pre-Classification option is intended for participating
accounts and will be conducted in the AFT Center’s virtual
environment.
  The Partnership Branch welcomes feedback and input from the
AFT industry on its implementation.
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ENFORCEMENT
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Apparel, Footwear and Textiles Import Highlights
  $131.6 billion in footwear, textile, wearing apparel products
come into the U.S. (5.5% of all imported value)
  Top 5 countries of origin account for 66% of these imports
  China ($58.5 billion)
  Vietnam ($9.6 billion)
  India ($6.5 billion)
  Indonesia 4 ($6.2 billion)
  Mexico ($5.8 billion)
  Over 64,800 entities import footwear, textiles and wearing
apparel
  378 entities are ISA (23.9% of imported value)
  3,144 entities are C-TPAT partners (62.1% of imported value)
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Apparel, Footwear and Textiles vs. All
Imports
Textiles
CEE
Importers
Lines
Value
Duty
FY12
Importers
Lines
Value
Duty
FY2010
FY2011 FY2012
64.5K
64.2K
64.9K
12.4M
13.5M
15.2M
$117.7B $133.0B $132.8B
$12.3B
$14.1B
$14.0B
%CHG
FY11-12
1%
13%
0%
0%
Industry Total All Imports % Overall
64.9K
307.8K
21%
15.2M
123.7M
12%
$132.8B
$2.4T
6%
$14.0B
$30.0B
47%
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Enforcement
  Focus on areas of risk
1.  Intellectual Property Rights
  59% of all FY 12 IPR seizures
  Undermine domestic producers
2.  Trade Agreements
  14% of imported value claims preferential treatment
  False preferential claims undermine trade agreements
3.  Revenue
  Duty collected by CBP on textile and apparel goods still accounts for
more than 40% of all duties
  Misclassification and undervaluation are schemes to evade high duty
rates on textiles and footwear
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AFT CEE Enforcement
  Enforcement activity can take place at time of entry or at postrelease.
  Some main areas of focus include, but are not limited to the
following:
  Intellectual Property
  Free Trade Agreements
  Revenue evasion
  Transshipment
  Enforcement actions involving participating accounts will be
coordinated with the Center prior to issuance.
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Allegations
  Allegations can be submitted by the trade directly through the e-Allegation
(cbp.gov), a Field Office, a Port of Entry or the designated CEE.
  Within e-Allegations, the Report Trade Violations is to be used to report the
following illegal trade activity:
  Misclassification of imports
  Country of Origin marking issues
  Textile/Trade violations
  IPR infringement
  Export issues
  Healthy and Safety Issues.
  All allegations affecting a participating account are to be forwarded to the
CEE.
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AFT CEE Operations
  The goal of our operations is to identify specific violators and
take appropriate action without negatively impacting the entire
textile/wearing apparel/footwear industry.
  In addition, our operations will focus on protecting our
participating accounts from illegal importing/exporting of their
products.
  The AFT CEE will work with the participating
accounts to establish concepts/plans for future
operations.
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Special Operation
 Joint operation by:
  AFT-CEE
 PORT OF ENTRY
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Operation Results
•  Four Day Operation
•  Total Intellectual Property Rights Seizures: 147
•  Total Manfr’s Suggested Retail Price: $1,132,414
•  Total Domestic Value: $385,305
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IPR Recordation
  The AFT CEE recommendations all Intellectual Property is recorded with
CBP.
  CBP can provide a webinar on How to Record IPR with CBP.
  All product manuals with recorded trademarks can be submitted to CBP for
inclusion in our internal Product ID Guide.
  The IPR Product ID Guide allows all CBP personnel (e.g., Officers, Import
Specialists, Entry Specialists, etc.) immediate access to the recorded
trademarks.
  The IPR Product ID Guide is only for CBP use and can not be viewed by
outside stakeholders.
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AFT CEE Enforcement Branch
  The AFT CEE Enforcement Branch is comprised of Import
Specialists, Supervisory Import Specialists, International Trade
Specialists, Supervisory International Trade Specialists, Trade
Program Managers, Operations Specialists, Asst. Port
Directors, Auditors, Supply Chain Security Specialists, and
Field Analysis Specialists.
  The Enforcement Branch currently contains Core and Matrix
members.
  The AFT Director has direct oversight of the Enforcement
Branch as the Asst. Director and Enforcement Branch Chief
conduct day to day operations.
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COMPLIANCE
&
VALIDATION
(coming soon)
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What Now?
  Apply to be part of the Apparel, Footwear & Textile
Center under the current Federal Register Notice
  Contact:
Dora Murphy
Assistant Director, Field Operations, Trade
Apparel, Footwear and Textiles Center Director
San Francisco Field Office
U.S. Customs and Border Protection
[email protected]
(415) 744-1530 x 233
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