International Manufacturer Shipping Requirements
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July 3, 2007
Dear Participating Manufacturer:
The National Law Enforcement and Corrections Technology Center (NLECTC)-National, the program of the National Institute of Justice (NIJ) that operates NIJ's voluntary compliance testing programs for public safety equipment, has recently completed a thorough review of its practices and policies related to the importation and exportation of items submitted to the NIJ compliance testing program.
As a result of this review, in order to ensure full compliance with current U.S. import and export laws and regulations, NLECTC-National has significantly amended its policies regarding receipt and transfer of items submitted to NLECTC-National from non-U.S. manufacturers for the purposes of NIJ compliance testing. This correspondence summarizes those amendments, which are effective immediately and supersede any prior instructions issued by NLECTC-National.
Laws and regulations pertaining to the importing and exporting of test items vary significantly depending on the country where these items originate or are returned, as well as the specific type of equipment to be shipped. NLECTC-National strongly encourages manufacturers to contact the representatives of DHL Global Forwarding to determine the specific procedures and fees that apply.
DHL Global Forwarding has been designated as NLECTC-National’s official freight forwarder and customs broker. All imports of products submitted to the NLECTC-National compliance testing program, as well as exports of products returned posttesting by NLECTC, must be handled through DHL Global Forwarding. This procedure requires manufacturers to establish an account with DHL Global Forwarding for shipments submitted to NLECTC-National for compliance testing, if they do not already have one established with DHL Global Forwarding.
Furthermore, manufacturers outside of the United States currently on file as participating in NIJ’s voluntary compliance testing program will be contacted in the near future by a representative of DHL Global Forwarding to establish an account. If you wish to contact DHL Global Forwarding directly, you may contact Cheryl Stewart at DHL Global Forwarding by telephone at (678) 479-2880, by fax at (770) 996-1174 or by e-mail at Cheryl.stewart@dhl.com. The official contact information for DHL Global Forwarding is:
DHL Global Forwarding
540 Airport Parkway South, Ste. 100
Atlanta, GA 30349
Internet: http://www.dhl-dgf.com
It is important to note that all shipments must be tendered on Door to Door Prepaid (DDP) terms because the manufacturer will still be responsible for all shipping, customs duties, taxes and other costs associated with importing and exporting items to and from NLECTC-National. By establishing an account with DHL Global Forwarding, manufacturers will be automatically invoiced for these charges. We anticipate these changes will streamline the compliance testing process and ensure the proper and timely receipt of items submitted for testing, eliminating any unnecessary delays in the import/export process.
Temporary importations and permanent exportation of Body Armor Level III & IV are controlled by the U.S. Department of State; however, permanent importations are controlled by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) and do not require a license. The manufacturer is responsible for determining and complying with U. S. requirements pertaining to each shipment; however, it is recommended that manufacturers send shipments as permanent importations. Please refer to United States Regulations Title 22 for specific requirements, paying close attention to 22CFRPart 123.1 and Part 126.13.
At the present time, it is NLECTC-National’s understanding that handcuffs, stab-resistant armor, protective gloves and body armor level I through IIIA are not controlled on importation or exportation. Please be advised that NLECTC-National will not be the consignee or importer, nor accept weapons from a non-U.S. manufacturer. Non-U.S. manufacturers must consign weapons to their U. S. agent and/or subsidiary.
Generally, licenses must be signed by an entity incorporated to conduct business in the United States and/or a U.S. citizen or national. Therefore, as an option, manufacturers having U.S subsidiaries or designated agents located in the continental United States are encouraged to submit their products to NLECTC-National through these subsidiaries and/or agents. Non-U.S manufacturers electing to submit products to NLECTC-National through their U.S. subsidiaries or designated agents must provide NLECTC-National with a complete list of those U.S. subsidiaries and/or authorized agents, including:
Manufacturers must include documentation verifying the U.S. subsidiary/authorized agent has the appropriate licenses, as applicable, to import and export the items submitted to NLECTC-National. In addition, a commercial invoice with the specific information set forth in U.S. Customs’ regulations is required for importation. U.S. regulations are the only authority for importation and exportation. Attached is a sample invoice that may be used as reference only. Reduced duty rates may be available in accordance with a free trade agreement with the U.S. Government. Per U.S. Customs Binding Ruling NYR02990, HTS# 9817.85.0100 should be used for the ballistic-resistant and stab-resistant body armor being imported for testing purposes only; however, this is a special U.S.-only classification and cannot be used as the Schedule B on exportation.
In the event that a manufacturer requires test samples to be returned to them that were originally sent to NLECTC-National as permanent imports, the manufacturer’s U.S. agent, acting as Importer of Record, must apply for and provide NLECTC-National with a valid copy of the required State Department License DSP-5, and provide proof that the U.S. agent is acting as a U.S. Principal Party in Interest on exportation.
Links to United States agencies regulating import and export include, but are not limited to:
Another change affecting the submission of items for testing is that non-U.S. manufacturers submitting items for testing must now provide advance notice to, and receive authorization from, NLECTC-National before submitting samples for compliance testing. This is to ensure that unauthorized items are not submitted to the program.
Manufacturers should provide a detailed listing of the test samples to be submitted, approximate size and weight of shipment, and number of boxes/containers. This listing may be submitted to NLECTC via e-mail at asknlectc@justnet.org or by fax to (301) 519-5149, no later than five business days prior to the anticipated shipment date.
On receipt of this declaration by the manufacturer, NLECTC-National staff will contact the manufacturer within three to five business days with an authorization number, which must be clearly marked on all packages to be shipped. Any package submitted to NLECTC-National without an authorization number will not be accepted by NLECTC-National.
We thank you for your continued participation in, and support of, NIJ’s voluntary compliance testing programs. If you have any questions regarding these matters, or if we can be of assistance, please contact the Compliance Testing Program staff at NLECTC-National by telephone at (301) 519-5060, by fax at (301) 519-5149 or by e-mail at asknlectc@justnet.org.
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