July 2012

TTB Issues Interim Policy for Labeling Gluten-Free Spirits

On May 24, 2012, U.S. Alcohol and Tobacco Tax and Trade Bureau (TTB) issued an Interim Policy on Gluten Content Statements in the Labeling and Advertising of Wines, Distilled Spirits, and Malt Beverages (TTB Ruling 2012-2).

Currently, there is no Food and Drug Administration (FDA) regulation that defines the term “gluten-free”. 

FDA proposed to define gluten free as:

  • an ingredient that is a species of wheat, rye, barley, or a crossbred hybrid of these grains;
  • an ingredient derived from these grains and that has not been processed to remove gluten;
  • an ingredient derived from these grains and that has been processed to remove gluten, if the use of that ingredient results in the presence of 20 or more parts per million (ppm) gluten in the food; or
  • 20 ppm or more gluten.

Pending the issuance of a final rule by FDA, TTB is providing interim guidance on the use of the term “gluten free” on alcohol beverage labels and advertisements subject to TTB’s authority.

Alcohol Products Made from Gluten-Free Materials

TTB’s position is that the term “gluten-free” will be interpreted by consumers of alcohol beverages to mean that the product contains no gluten. TTB provided the example of wine fermented from grapes, or vodka distilled from potatoes. If  there are good manufacturing practices – meaning no cross-contamination, no additives, no yeast, and no storage materials with gluten – a ‘gluten-free’ claim in the labeling of the alcohol beverage will be permissible in the interim period awaiting FDA’s final rule.

Alcohol Products Made from Gluten-Containing Materials

FDA and TTB […]

By |2022-07-06T13:52:25-04:00July 20, 2012|Food|0 Comments

China Sourcing Fair – How to Solve U.S. Customs Issues When Importing From China

 The rewards of sourcing from China are well known, but succeeding at it is far from simple. With a sluggish global economy resulting in unpredictable market changes, cost-effective sourcing is important.

To help you build or sharpen your China sourcing strategies, I am thrilled to be part of a new series of “How to Source from China” conferences at the China Sourcing Fair (July 10-12, Miami)!

The conferences are led by industry experts, and reveal real-life sourcing risks in China. We will share actionable knowledge at every step as the project moves from concept to delivery, and the conference will offer in-depth insights and practical tips on do’s and don’ts of China sourcing. Whether you’re a beginner or veteran buying professional, the FREE conference program is your chance to learn how to source efficiently and effectively from the “world’s factory”.

Register now to enhance your importing skills and knowledge today! Conference seats are limited and are on a first-come, first-served basis.

I will be speaking on “How to Solve U.S. Customs Issues When Importing From China”.

Intellectual property rights (IPRs) are a priority trade initiative for U.S. Customs. Most confiscated China imports violated US Customs’ IPR laws, which should serve as a reminder when buying from China.

In my seminar, we will look at ways of preventing and dealing with these issues. In particular, we will cover:

  • Trademark / copyright violations (What U.S. Customs looks for)
  • Top […]

Free Trade Zones Expanding in Miami-Dade County

PortMiami wants free trade zones (FTZ’s) throughout Miami-Dade county.

As we know, PortMiami is currently dredging to 50 feet in pursuit of the post Panamax ships, and wants to prepare for the massive amounts of cargo PortMiami looks forward to receiving as a result of the dredging project.  In preparation, PortMiami is looking to the South Florida business community to get engaged and prepared as well.

Under PortMiami’s plan, any business north of Southwest Eighth Street could apply for free-trade status (under FTZ 281) and be exempt from import duties (for example, for cargo heading abroad). There are many benefits to an FTZ, ultimately resulting in duty savings.

The Miami Herald reported that PortMiami’s application is expected to receive approval by the summer (UPDATE – PortMiami has officially been approved and operates FTZ 281), which will allow local businesses the opportunity to apply for foreign-trade zone status, enabling them to utilize their FTZ for duty savings, as goods shipped into a FTZ that are destined for export are exempt from paying CBP duties.  Many companies use South Florida as a transhipment hub, purchasing goods from China, using South Florida as a distribution center, and then selling those goods to customers in South America.  Using a FTZ saves the importer from having to pay customs duties on imports for exports.

The Beacon Council – Miami-Dade County’s official economic development partnership – has coined trade/logistics and aviation as two of the ‘seven pillars’ of Miami-Dade County in the One Community, One Goal […]

CBP’s Pointers on Exporting Used Vehicles

Last week, I attended a seminar hosted by U.S. Customs & Border Protection (CBP) at the Miami Free Zone regarding exportation of used vehicles such as cars and automobiles. Here are the highlights:

CBP’s ’72-Hour Rule’

CBP regulations require the exporter of a vehicle to submit all export documents to the port of entry from which the vehicle will be exported at least 72 hours prior to export. Documentation for U.S.-titled vehicles include an original certificate of title. For used, self-propelled vehicles a current Certificate of Title or a Salvage Title issued by any jurisdiction in the United States is required.

What if the car has ‘Foreign Title’?

For vehicles that are registered or titled abroad, the owner must provide to CBP the original document that provides satisfactory proof of ownership (with an English translation of the text if the original language is not in English), and two complete copies of that document (and translation, if necessary). Important Note: Failure to have translated copies on hand will result in CBP delaying your importation.

What if it’s a ‘Junk’ car?

Junk Cars mean vehicles not to be sold as a whole. Junk cars require salvage title or a certificate of destruction. Destruction documentation is provided on the state level. Note: Certificates of destruction can only be reassigned twice in the State of Florida.

What […]

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