Food Facility Registration Period Now Open (From Sandler, Travis, and Rosenberg)
…Under the Food Safety Modernization Act, all foreign and domestic facilities that manufacture, process, pack, or store food, food ingredients, pet foods, or dietary supplements are required to renew their registrations with the FDA every even-numbered year…
…Failure to register can result in the facility being prohibited from importing or exporting food into or from the U.S., offering to import or export food into or from the U.S., or otherwise introducing food into interstate or intrastate commerce. Failure to submit, renew, update, or cancel a registration can also result in civil or criminal action…
…Foreign and domestic food facilities, as well as the companies that source from them, should ensure those facilities renew their registrations on time. The current renewal period opened Oct. 1 and will close Dec. 31. Renewals are mandatory regardless of when the initial registration occurred.
…When registering, foreign food facilities must also designate a U.S. agent, a person or entity that is located or maintains an office in the U.S. and acts as the facility’s domestic representative through which all communication with the FDA takes place. U.S. agents must confirm that they have agreed to serve as such and the FDA will not confirm a registration or provide a registration number until the U.S. agent has provided this confirmation.
Ed. Note: We cannot be your U.S. agent. We will gladly provide you a list of reputable companies that provide this service for a fee.
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Airfreight rates on key lanes continue gradual descent in September (From Air Cargo News)
Airfreight rates on key trade lanes out of Asia continued to weaken in September despite the industry heading towards the peak season.
The latest figures from the Baltic Exchange Airfreight Index (BAI) show that in September rates from Hong Kong to North America declined by 18.5% compared with a year ago to $7.94 per kg and are also down on the $8.33 per kg achieved in August.
The declines are noteworthy for two reasons, firstly rates on the trade lane tend to increase from August to September and secondly it is only the second time since February 2020 that prices on the trade have registered a year-on-year decline. For more info, please go to
Lufthansa Cargo decreases Airfreight Surcharge to 0.80 USD per kg
Lufthansa Cargo is decreasing its Airfreight Surcharge, effective October 10, 2022, from 0.85 to 0.80 USD per kg chargeable freight weight. Please note, the AWB issue date, not the flight date, determines the applicable Airfreight Surcharge.
List of Goods Produced by Child Labor or Forced Labor (From Dept of Labor)
The Bureau of International Labor Affairs (ILAB) maintains a list of goods and their source countries which it has reason to believe are produced by child labor or forced labor in violation of international standards, as required under the Trafficking Victims Protection Reauthorization Act (TVPRA) of 2005 and subsequent reauthorizations. The List of Goods Produced by Child Labor or Forced Labor comprises 158 goods from 77 countries, as of September 28, 2022.
ILAB maintains the List primarily to raise public awareness about forced labor and child labor around the world and to promote efforts to combat them; it is not intended to be punitive, but rather to serve as a catalyst for more strategic and focused coordination and collaboration among those working to address these problems.
Publication of the List has resulted in new opportunities for ILAB to engage with foreign governments to combat forced labor and child labor. It is also a valuable resource for researchers, advocacy organizations and companies wishing to carry out risk assessments and engage in due diligence on labor rights in their supply chains. The list is at:
https://www.dol.gov/agencies/ilab/reports/child-labor/list-of-goods
Ed Note: Customs is aggressively investigating suspected imports made with child or forced labor. We urge you to take aggressive steps to insure your supply chain is totally free of these.
Final Exclusions Expiring (From Meeks, Sheppard, Leo, and Pillsbury)
The Section 301 exclusions that were extended by USTR on March 28, 2022, retroactive to goods entered or withdrawn from warehouse for consumption on or after October 12, 2021, are set to expire on December 31, 2022. There are also 81 exclusions related to Covid/Medical-Care products that are set to expire on December 1, 2022. So far, the USTR has declined to consider further requests for exclusion, despite significant pressure by importer groups to do so.
Reminder: Some CBP fees changed Oct 1
The Merchandise Processing Fee (MPF) ad valorem rate of 0.3464% will NOT change. The MPF minimum and maximum for formal entries (class code 499) will change. The minimum will change from $27.75 to $29.66; and the maximum will change from $538.40 to $575.35. For the complete schedule, please go to
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