World Trader | September 2018

Midwest Global Trade Association

From the President

Upcoming Events

Moving to EAR License Exceptions after Export Control Reform

Company Spotlight

Thank You, Newsletter Sponsor: Port of Seattle

From the President


By Amanda McDonald — MGTA President

Amanda McDonald

It is hard to believe that the summer is almost over.

The golf event was amazing, the weather was great, and drinks were cold!

As the year as progressed, MGTA has offered several seminars over varied topics. But I still feel that as an organization we could do more. With that in mind, MGTA will be starting up a message board. I am hoping to use this as a community board for questions, shared resources and assistance. We are a community of Trade individuals and I want to create a place for great minds to come together to share the wealth of knowledge we have proudly cultivated through our years of service.

So, be on the lookout for the message boards coming up soon. But remember, you have to login to the MGTA site to access the message boards. If you are having troubles signing in, please let us know.

Amanda McDonald

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Upcoming Events

Duluth Field trip – Learn About FTZ, Warehousing, and Port Options

  • Date: Wednesday, September 19, 2018
  • Location: 95th Avenue Park and Ride
    3629 95th Ave NE
    Circle Pines, Minnesota 55014
  • Register Now

Program Description:

Join MGTA on a fieldtrip to Duluth to learn how the Port of Duluth can support your domestic and global trade. This full-day event provides a great opportunity to learn about Duluth’s free trade zone, warehousing, and port transportation options.

In addition, we have arranged plant tours of two international companies: ME Global and Cirrus Aircraft. The tours provide views into their product production and how they support their international customers. Please note that the Cirrus Aircraft tour requires U.S. citizens show a valid driver license and non-US citizens must provide a passport.

The day includes coach bus transportation (with wifi) from the Twin Cities to/from Duluth – just show up and enjoy a relaxing day with other trade professionals. Lunch will be provided.

Port of Duluth-Superior – Duluth Cargo Connect

Duluth Cargo Connect provides seamless cargo handling, storage, distribution and transportation logistics services for breakbulk, heavy lift and other project cargoes moving in and out of the Port of Duluth.

While Duluth-Superior port has been known as the Great Lakes "bulk cargo capital” and ranked in the nation's top 20 ports, it now offers a full-service, multimodal hub for domestic and international trade. At the crossroads of three major highway systems and four Class I railroads - BNSF, CN, CP and UP - it is ideally situated for moving containerized cargo in and out of the heartland. This, combined with Duluth’s free trade zone and warehousing options, provides options worth exploring.

ME Global

ME Global, is a division of the 101 year old company ME Elecmetal. Founded in 1917, ME Elecmetal is a leading company in the mining industry providing total solutions for mineral processing worldwide. The Duluth Minnesota plant uses electric arc furnaces and vacuum molding systems to produce products serving mining, construction, and industry.

ME Global Inc. d.b.a. ME Elecmetal, is a wholly owned subsidiary of the 101 year old company Compañía Electrometalúrgica, S.A. (Elecmetal) located in Santiago, Chile. Both companies were founded in 1917. ME Elecmetal acquired ME Global Inc. in 2001 and are both leaders in the mining industry, providing wear parts and total solutions for mineral processing worldwide. ME Elecmetal has foundry facilities in Rancagua, Chile; Changzhou, China, Tempe, AZ and Duluth, MN. The Duluth Minnesota plant uses electric arc furnaces and vacuum molding systems to produce products serving the mining, aggregate, and construction industries. http://www.me-elecmetal.com/en/

Cirrus Aircraft

Cirrus Aircraft is a recognized leader in general aviation, with its all-composite line of personal aircraft. Cirrus incorporates innovative and advanced performance, electronic and safety technologies, including avionics and the unique Cirrus Airframe Parachute System. Cirrus exports their aircrafts internationally.

Hope you can join us!

Who Should Attend:

  • Supply Chain / Logistics staff supporting domestic or international transportation and shipments
  • Import Brokers
  • Freight Forwarders

Learning Objectives:

  1. Understand the function and benefits of a free trade zone.
  2. Learn about the services and benefits of the Duluth Port warehouse.
  3. Understand the Duluth-Superior Port multimodal cargo hub services and transportation options.
  4. Gain familiarity with Cirrus Aircraft and ME Global production, supply chain, and transportation

Agenda / Schedule:

7:00-7:30 Registration / Check-in – Must arrive before 7:30 a.m.

95th Avenue Park and Ride
3629 95th Ave NE
Circle Pines, MN 55014

7:30 am Bus leaves - Lorenz Bus company to travel to Duluth
9:45 am Arrive - ME Global (Duluth) tour
11:15 am Lunch (provided by Agility Logistics)
12:00 pm Bus – travel to Cirrus Aircraft
12:30 pm Cirrus Aircraft tour
2:15 pm Bus – travel to Duluth Port
2:30 pm Duluth Port, FTZ, and Warehouse tour
3:45 pm Bus – travel back to Twin Cities
5:45 pm Arrive - 95th Avenue Park and Ride

*Bus has wifi internet access

Speakers

Pete Kramer

General Manager
Duluth Cargo Connect

Pete Kramer is the General Manager of Lake Superior Warehousing Co., Inc., a company that partners with Duluth Seaway Port Authority to create Duluth Cargo Connect. He supports warehousing and transportation services through the Port of Duluth.

Jonathan Lamb

President Lake Superior Warehousing
Duluth Cargo Connect

Jonathan Lamb is a transportation executive in the logistics and warehousing industry. He is a sales professional skilled in Operations Management, Supply Chain Optimization, Freight, Reverse Logistics, and Ocean Transportation.

Fee

Member: $125
Non-Member: $190
Student: $35

Reminder

  1. Participants need to wear closed toed shoes and long sleeve clothing
  2. US Citizens will need their driver licenses and Dual/non US Citizens will need their passport

Register Now

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Moving to EAR License Exceptions after Export Control Reform

By Visual Compliance (eCustoms)
https://www.visualcompliance.com/

For exporters of United States Munitions List (USML) goods, technologies, and services, the License Exemptions in the International Traffic in Arms Regulations (ITAR) are engrained, a way of life.

One of the disruptions to familiar procedures for defense-related companies with items reclassified to the Commerce Control List (CCL) under Export Control Reform (ECR) is the corresponding switch to using (and therefore learning) the Export Administration Regulations (EAR) License Exceptions that might apply. For CCL 600 Series and 9X515, ITAR Exemptions are no longer in the picture.

This article highlights some of the commonly-used EAR Exceptions for 600 Series and 9X515—these being TMP (740.9), RPL (740.10), GOV (740.11), and STA (740.20).

Temporary Imports, Exports, Reexports, and Transfers (In-Country) Exception

Temporary Imports, Exports, Reexports, and Transfers (In-Country) Exception (TMP) authorizes various temporary exports and reexports, including ‘tools of the trade’ and items for exhibition or demonstration; exports and reexports of items temporarily in the United States, including personal protective equipment; and exports and reexports of beta test software. Related to TMP, the Servicing and Replacement of Parts and Equipment Exceptions (RPL) specifically authorizes “exports and reexports associated with one-for-one replacement of parts, components, accessories, and attachments.”

RPL also authorizes exports and reexports of certain items currently subject to the EAR “to or for, or to replace, a defense article described in an [ITAR] export or reexport authorization” (although does not authorize the export or reexport of defense articles subject to the ITAR). The main change from the ITAR with the use of these is that the EAR does not control temporary imports into the United States, therefore an authorization or license exception is not required for 600 Series and 9X515 items coming into the U.S. for repair or for trade shows. [i]

Governments, International Organizations, International Inspections Under the Chemical Weapons Convention, and the International Space Station

Exception GOV represents Governments, International Organizations, International Inspections Under the Chemical Weapons Convention, and the International Space Station, and authorizes exports and reexports for international nuclear safeguards; U.S. government agencies or personnel; agencies of cooperating governments; international inspections under the Chemical Weapons Convention; and the International Space Station. In effect, GOV authorizes exports for the agencies and the personnel of the U.S. government, including contractor support personnel, and also certain exports for cooperating governments, which are not found in ITAR Exemptions.

License Exception Strategic Trade Authorization

STA is the License Exception Strategic Trade Authorization, created under Export Control Reform. STA authorizes “exports, reexports, and transfers (in-country), including releases within a single country of software source code and technology to foreign nationals, in lieu of a license that would otherwise be required pursuant to part 742 of the EAR.” Therefor this exception is, in practice, an alternative to a license for applicable 600 Series and 9X515 items. STA eligibility is limited to the thirty-six Country Group A:5 countries and U.S. government end-use. There are a number of requirements to meet, and as well each STA-eligible ECCN contains a statement of “Special Conditions for STA” in the License Exceptions section. Similar to Commerce license requirements, a Prior Consignee Statement (PCS) is needed for prior authorization, with notifications to BIS of ECCNs and ultimate end-user and shipment information, also written notifications to the consignee of STA shipments. Which means that STA entails similar up-front work to a license, but with the benefits of faster approvals, that it covers technology, permits retransfers and reexports, and a single PCS can be used for multiple shipments.

As with a license, the key to smooth passage is ensuring that complete and full documentation is provided to the agency when submitting for review, including a statement of how the prior verification check was performed, and if any 600 series items are for Major Defense Equipment. BIS offers an online STA tool to help you at https://www.bis.doc.gov/index.php/statool.

Best practice for the use of BIS License Exceptions is to study and keep informed of the EAR regulations, the same expertise that you have with ITAR. For STA especially, consult with a BIS field office to create a checklist of requirements, then document your steps, be thorough, reply to questions from the agency promptly, and don’t use an Exception if you don’t have a license requirement for the item.


[i] More information about the Licenses and related-regulations referenced in this article can be found on https://www.bis.doc.gov/.

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Company Spotlight

Federal PremiumFederal Premium, headquartered in Anoka, MN, is a brand of Vista Outdoor Inc., an outdoor sports and recreation company. From humble beginnings nestled among the lakes and woods of Minnesota, Federal Premium Ammunition has evolved into one of the world's largest producers of sporting ammunition. Beginning in 1922, founding president, Charles L. Horn, paved the way for our success. Today, Federal carries on Horn's vision for quality products and service with the next generation of outdoorsmen and women. We maintain our position as experts in the science of ammunition production. Every day we manufacture products to enhance our customers' shooting experience while partnering with the conservation organizations that protect and support our outdoor heritage. We offer thousands of options in our Federal Premium and Federal® lines-it's what makes us the most complete ammunition company in the business and provides our customers with a choice no matter their pursuit. For more information on Federal, visit www.federalpremium.com.

Fast Facts:

  • Headquartered in Anoka, Minnesota
  • Manufactures a complete line of shotshell, centerfire and rimfire ammunition and components
  • Market leader in ammunition technology
  • Part of the world's leading ammunition manufacturer, Vista Outdoor
  • Nearly 1,400 employees work at the Anoka, Minnesota facility
  • The facility is located on 175 acres in Anoka County and spans the border of Anoka and Coon Rapids with half a million square feet of manufacturing space
  • Federal Premium Ammunition is the company's flagship brand and focuses its competitive advantage on cutting edge technology
  • As an active business in the local community, Federal Premium has been responsible for abundant employment opportunities and community involvement throughout its history

To learn more about our rich history, please visit our Facebook Timeline »

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