Global Sourcing & Purchasing Post 9/11: New Logistics Compliance Requirements and Best Practices

REVERSE LOGISTICS IN THE CONTEXT OF IMPORTING

The term "reverse logistics" represents import shipments that are manufactured in the U.S. and exported across U.S. borders, then returned to the U.S. for a particular reason, such as a customer rejection or complaint or perhaps a product returned from abroad after further manufacturing or repair. When a clearance process for reverse logistics is set up properly, duty payment is avoided. Returned goods are duty free under Customs law if the appropriate documentation is established. Setting up an efficient reverse logistics process will also expedite turnaround time and reduce compliance risks. A database covering all requirements for returned goods should be created to capture a U.S. contact name, import requirements, declarations, and forms to establish the reimportation of a product for U.S. clearance. The foreign supplier has an obligation to complete Exporter Declaration forms; the importer, as well, has an obligation to complete any Importer Declaration form coinciding with the returned product. The information on the form must be completed accurately and made readily available for clearance prior to its scheduled return date. The various returned goods forms can be found on the Customs website.

In the case of food-related U.S.-manufactured products, such as vitamins that are returned to the U.S. for quality control analysis, the shipment may be subject to the Bioterrorism Act and require a Prior Notice (Chapter 5) clearance even if the intended use is not as a consumed product. Contacting the Regulatory Affairs (RA) Department to review this situation...

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