Flexport Advises Designating Who Is Responsible for Filing E-Certificates to CPSC
As importers prepare to comply with the Consumer Safety Product Commission's plan to require the electronic filing of certificates starting July 8 (see 2601080077), companies should carefully consider who should be the role of "business administrator," or the one who will e-file the certificate, Flexport's Zach Claussen said during a webinar this week on the upcoming requirement.
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That's because the business administrator will be the one deciding how to file the certificates and what product categories should be made when filing, said Claussen, a Flexport customs manager.
"The most important person in all this is going to be the business administrator. They should be the one who's setting up the account," Claussen said. "I kind of liken this to the ACE portal account holder -- someone that might not necessarily be inputting all of the data, but someone that's going to be with the company for a long time, an active participant in the company that can navigate, knows the ins and outs of CPSC, from the highest of highs to the lowest of low details."
What's distinctive about the business administrator is that he or she is the one who will be ultimately responsible for making the product categories, according to Claussen. For example, a company that imports both toys and bicycles will need to set up individual product types for each kind of good, and within those, establish SKUs or the product identification numbers.
The business administrator will also be able to assign other roles, such as the collection administrator and the collection editor, who would be responsible for adding information on the products themselves, or the collection viewer, he said.
Importers typically have given customs brokers viewer access, although they may choose to provide cross-functional access and give brokers greater responsibility in receiving CPSC data, according to Claussen.
Importers ultimately are "going to need to decide how much visibility you want to give to your manufacturers, your customs brokers, things like that," Claussen said. "The cross-functional access is great, but ultimately, the importers are responsible for maintaining your databases. So, brokers won't be able to go in there and fix anything. We can pull the information that you provide." CPSC also has outlined who does what when it comes to permissions within the e-filing platform, Claussen continued.
Whoever is filing the customs declaration would ultimately take on the responsibility and liability for CPSC, said Marcus Eeman, director of customs at Flexport.
Claussen also advised webinar participants that importers should double-check with CPSC whether their products would require a certificate because not all applicable HTS codes may be input into ACE. "Products being imported under other HTS codes may still require certification," he said. Claussen was responding to a question about whether a company should register one's products -- which fall under heading 6911 -- if doing so is not explicitly required.
Another question was whether goods categorized under Harmonized Tariff Schedule code 9801.00.1098 were impacted. Eeman answered that since PGA requirements are generally the same whether or not a product has been reimported previously, the company may still need to show that it satisfies the same requirements.
"Fully expecting to maybe not necessarily flag, but if you, as an importer, wanted to say, yes, I want to claim this product under 9801.00.1098 and I know my due diligence, I also want to proactively provide this information to CPSC. You can always ask your broker to force claim this option," Eeman said.