Working Together for Trade

December 15, 2021

AAEI committees respond to specific global trade concerns, bringing needed information to members and members’ views to the attention of key policy makers and administrators. Members’ common concerns and potential areas of difficulty are addressed through the committee framework. Our substantive committees include:

Chemicals, Oil & Gas Committee

Focuses on issues of interest to importers and exporters of chemical and petroleum products, other bulk commodities, and related transportation companies.

Customs Policy and Procedures

Focuses on projects dealing with automation, entry revision, global customs harmonization, trade security, tariff data reporting, ISF, bonds and legislation impacting the trade community.

Gains:

  • Established ongoing dialogue with Sen. Bill Cassidy’s office on proposed draft legislation to modernize U.S. Customs law.
  • Filed comments on CBP Broker Continuing Legal Education Regulations
  • CBP granted AAEI extension request to file comments on new USMCA Rules of Origin Regulations   
  • Filed Comments to CBP on USMCA Rules of Origin Regulations   
  • Called for Allowing Importers to Choose Best Method     
  • Called for Impact Study           
  • Revived Administration Transition Meetings   

Next Goals:   

  • Follow up with CBP on USMCA Regulations and Country of Origin Determination
  • Preparing Members for CTPAT for Compliance

Drawback and Duty Deferral

Focuses on regulatory changes and administrative concerns regarding all types of duty drawback and special duty deferral programs.  Its goal is to get the Drawback Modernization Act passed immediately and to work with CBP to automate the entire drawback process in ACE.

Gains: 

  • Reported first on CBP Drawback specialists’ moves & assignments at The Centers.
  • Filed Comments on Preserving Drawback Benefits in New USMCA Regulations 
  • Continuing AAEI’s Progress on Implementation of Simplified Drawback for Filers 
  • First to Report on CBP’s Alignment of Drawback Specialists with Centers for Excellence and Expertise 

Next Goals: 

  • Leading CBP Drawback Working Group  
  • Continuing Work with CBP to Preserve Drawback Benefits 
  • Preparing Members for CTPAT for Compliance

Export Compliance and Facilitation

Focuses on U.S. export controls, unilateral sanctions programs, and foreign barriers to U.S. exports.

Gains: 

  • Co-authored AAEI’s Port Congestion Letter to FMC Highlighting Burden on Exporters 
  • Called on Senate to Move Forward with Confirmation Process of BIS Under Secretary Nominee 

Next Goals: 

  • Pursuing Advocacy Steps for Export Modernization 
  • Alerting Government Agencies to Problems Stemming from 100% Cargo Screening 
  • Monitoring Government Publication of Long-Awaited Routed Export Rules 

Healthcare Industries

To engage with legislative bodies and federal agencies (FDA, USDA, DEA, EPA) to develop guidelines and workable solutions that facilitate the import and export of life saving drugs and medical devices and also assist the agencies to fulfill their mission to ensure public health and safety.

Gains: 

  • Contributed to AAEI’s Work on USMCA Rules of Origin Comments 

Next Goals: 

  • Improving System of Intended Use Codes 
  • Monitoring Development of FDA’s Import-for-Export (IFE) Program 
  • Improving Healthcare FTZ Compliance 

International Policy

Focuses on the global trade facilitation and compliance issues and needs of multinational companies and their service providers with global trade compliance teams overseas.

Next Goals: 

  • Restructuring the Committee 
  • Creating Trade Facilitation Metrics 
  • Monitoring Developments on Border Environmental Goods and Services Tax 

Member Services

Focuses on recruitment of new members, retention of existing members and development of member services and benefits.

Border Interagency

Focuses on the unique problems of importers subject to the regulations of FDA, USDA, EPA, CSPC, DOT, FWS, ATF and others.

Gains: 

  • Securing Modification of Shippers Declarations from CBP 
  • Re-Engaged Aerospace & Defense Center for Excellence and Expertise 

Next Goals: 

  • Linking E-docs to Single Window 
  • Using A.I. for Classification 
  • Monitoring CPSC Border Enforcement 

Textiles, Apparel and Footwear 

Focuses on the importing and exporting of textiles, apparel and footwear.

Gains: 

  • Provided AAEI Member Webinars on Forced Labor Enforcement Updates 
  • Discovered Backlog of CBP’s Withhold Release Orders (WROs) 

Next Goals: 

  • Monitoring for new WROs 
  • Lowering Duty Rates on Textiles 
  • Improving E-Commerce Compliance 

Trade Policy

Focuses on regional and special trade agreements, multilateral trade negotiations, dumping and countervailing duty issues, competition policy, legislation and macroeconomic policy as it affects international trade.

Gains: 

  • Pursued Forced Labor Investigative Timeline from CBP 
  • Successfully Advocated against Section 301 Tariffs on Imported Goods from Vietnam 

Next Goals: 

  • Getting Clarity from CBP on Forced Labor Best Practices 
  • Developing AAEI’s Position Paper on CBP’s 21st Century Customs Framework (21CCF) 
  • Calling for New China Phase 2 Talks 

Transpacific

With primary focus on logistical issues impacting Transpacific Trade, this committee would also identify Transpacific trade issues which impact all members.

Gains:

  • Led AAEI’s Ongoing Effort to Solve Port Congestion Problems 
  • Co-authored AAEI’s Port Congestion Letter to FMC Highlighting Burden on Exporters 
  • Contributed to Formation of Biden Supply Chain Task Force 
  • Contributed to Creation of Port Envoy and FMC Advisory Committee 

Next Goals: 

  • Supporting Passage of Ocean Shipping Reform Act of 2021 
  • Expanding AAEI Engagement with White House