CPSC eFiling Is Almost Here. Are You Ready?

Hello, good morning. Uh, welcome to today's CPSC webinar. Um, I'm your host today. My name is Marcus Eman. I'm a customs director here at Flexport. Our topic CPS-C e- filing is here July 8th. Are you ready? Um, I'm really hoping the answer is yes. And this is all just kind of a for fun meeting, but if it's not, um, please listen in closely. We have a lot of good content, advice. If you're new to our webinars, just a quick uh housekeeping lesson here. We have a um on our screen we have a sidebar on the right of the main stage where you can submit questions. At the end of our presentation we'll host a Q& A. We always try to answer as many questions as we can. Um and so there's been a lot going on in tariff news this week. So we are going to do a brief update from me on 301 and 232 but we do really want to focus on CPSC and try to keep to the topic as much as we can. Um at the top of the sidebar you also see a tab labeled documents. This is where you can download a copy of today's slides and find some other helpful resources like our tariff simulator. And as a brief legal note to get started here, please keep in mind that all of the information provided in this session is based on the situation at the current time and may not be customized to your specific business requirements. We always recommend reaching out to a Flexport expert uh for any particulars of your situation. Joining me today is my colleague uh Zach Clawson who is a senior customs manager for the south region here at Flexport. And here is our agenda for today. As I said, we are going to start with some tariff updates on section 301 and 232. Talk about a few of the things that have happened here at kind of a higher level um before we get into the meat of our presentation where we want to focus on CPSC. But these updates this week are just too timely and too important to just kind of gloss over. So, we are going to spend some time on that first, but we'll answer questions on both, then we're going to wrap up, uh, with a Q& A. So, uh, we can go on to the first slide here. All right. Okay. So, the 232 updates. So, this happened earlier this week here. And there the high level news is that there are some reductions to 232 duty rates. Um, but the scope is fairly narrow. narrow toward both agriculture use, um, agriculture, machinery, combines, harvesters, tractors, that sort of thing. residential HVAC equipment and what they're calling mobile industrial products, things like forklifts, bulldozers, mobile cranes, things of that nature. Um, several derivatives uh on this list kind of part of annex C6 to C8 are qualifying for this reduction. So going down from 25% down to 50%. Um, and a few things are have been added as well. So, you know, some photographic film and some steel racks are going to be now included on section 232. Um, but I just say like overall this is kind of a reduction for any of those particular products. There are additional reductions as well of a capped 15% rate for certain products that are exclusively used for the production of some of these things. So the mobile industrial equipment, the agricultural machinery, if you have some of these products that are in the C9 to C10 annex and they're in chapter 84 and 85 or 87 and if they're used exclusively uh for the production of some of those machines, you can also qualify for a lower rate there as well. Um the second major update here is that the US content threshold is being lowered across the board um from 85% to or I'm sorry to 85% from 95%. So back in April they, you know, announced, okay, there's a US content threshold. So if you use copper, aluminum, steel, um, and it's subject to 232, but 95% of that content comes from the United States production, smelting and casting and pouring all that. Um, then you can get a 10% rate, which is pretty attractive for the 50 and 25% alternatives. Um, but they've lowered that threshold to 85%. And if you were reading along in the announcement, you saw that they said if it's made entirely of US metal and then they define entirely as 85%. Um interesting use of the word there. But uh the good news is that threshold is just a little bit lower um for that to qualify for that really generous discount down to a 10% effective rate. Um and that is still also applies to the existing brakes in addition to the equipment um that just got uh updated here. Uh third major update is that the trade deal countries are getting a capped 15% on some of these mobile industrial goods. Remember these are cranes, bulldozers, back hoes, forklifts, things of that nature. Any of these countries that have like a trade deal worked out. So this is the 27 EU countries, Argentina, Ecuador, Salvador, Guatemala, the list is there. Um they get a 15% capped rate. So if you recall how the capp rates worked before for automotive or anything like that um or for the EU under IPA um it would basically be the IPA code uh was you know the difference between the base duty rate and 15%. It's similar here for section 232 as well. Um the fourth one is a bit odd. There is a reduction for USMCA content if you're importing um these mobile industrial

products. again, bulldozers, heavy kind of construction site equipment, um that's moving around. Uh you're allowed to do a value breakout. So, we got rid of value breakouts in April, but here they are again. We're bringing them back for purposes of USMCA. Um there's a 25% rate for these products that applies only to the new to the non- US content. So, the Canadian Mexican content or just non US content, um that only gets the 25% rate. the uh US content does not have to pay that 25% rate but only up to the US content being 40% of the article value. This effectively creates a 15% minimum rate which as we were working through the math and updating our terrace simulator. Um we notice that there's a weird uh cliff that occurs here. And just to kind of illustrate what this looks like visually can go [snorts] to the next slide. Um here let me move over. Suppose we have a $10,000 forklift under 8427104000 and we're importing this under USMCA. Uh the green line is just a percentage of the US content in this forklift and the blue line is the duty rate you're going to pay on this $10,000 forklift. So remember at 0% US content, there's nothing really to break out. So you pay 25% on a $10,000 forklift, you pay $2500. Okay? But and as you increase the amount [snorts] of US content, the amount of duty you pay goes down. So at 20% US content, you only pay $2,000 in duty, right? Because 20% is duty-free. You pay 25% on the remaining 8,000 non US content, right? 25% of $8,000, $2,000. Okay? So we're seeing a reduction. That happens again at 40%. And that gets down to 15% effectively, right? We have this $10,000 forklift. we're going to only pay $1,500 in duty on it. But something happens. They say after 40% you now have to go and pay 25% on the entire value. So at 40% US content, you're paying $5,100 or $1,500. Uh but then at above 40%, say 41% 42%, you now pay $2,500 in duty. This is a bit odd. Um it sort of means that the more US content you pay uh you or have the more you'll actually pay. This is a bit strange. Um but what I think is happening here um is talked about on the next slide is that at some point this uh 40% mark correlates and eventually flips over what is actually the country of origin for marking purposes. Remember that something that is the product of the United States is not subject to 232 duties. This has been true since um since the beginning of last year when they started doing these 232 duties. There's large exemptions based on if the product is made in the US, if it's for marking purposes, country of origin US, 232 does not apply. So I think the implication here is that supposedly at some number 60% US content 70% US content depending on the exact product it's more likely that you have um to be country of origin US and the 232 duties you pay go down to zero. Um but I don't think that's necessarily going to be the case for everybody. There's definitely going to be some odd situations where you don't meet the marking rules of 102 for purposes of, you know, country of origin determination for a USMCA country. It's still not, you know, country of origin US, but uh your value content may be 60% 70% US. So there's going to be some weird situations where people who maybe move production back to the United States, increasing the value ad there, but finishes it in Mexico, finishes it in Canada, may actually be paying more because they move production to the United States. Um, a little bit odd, but I think I see what they were trying to do here. But, uh, there are going to be some people with some unusual cases for these mobile industrial equipment importers. Okay, so that's 232. Um, we'll go on to section 301. We got news uh of some preliminary findings on the forced labor investigation. Now, remember there were two going on, forced labor and structural overcapacity. No update yet on the structural overcapacity as of this moment. Um watch closely. We could see something soon. And there's a few takeaways here. They created two tiers of a 10% rate for 13 countries plus the EU 27 12% on another 46 countries. And most of those trade deal countries that kind of had an arrangement and understanding memorandum, they are on that 10% list. Um, we'll go over the full list in a minute. The exclusions are also pretty clear as well and they sound pretty familiar. They sound pretty similar to IPA. Unavailable natural resources qualify. Banana, coffee, that sort of thing. Um, good subject to 232 would not be subject to these 301 duties. That also sounds like critical minerals and ore is exempt. chemicals, pharma, beef, um, civil aircraft also

exempt from these 301s. And USMCA and DRA CAFTA also get a break. So, in many cases, this looks a lot like some of the exclusions you were used to under IPA. It's just coming a little bit later. Um, what is a little bit odd about this one that we need to see more details on, I'm very interested in is seeing that the return of tariff rate quota being proposed for textiles. Remember a tariff-free quota means that after some number of products per year, you can bring it in duty-free or maybe at a lower rate of duty, but then after a certain volume of imports has been reached, the tariff rate jumps up for everybody over the course of a year. So, you know, the first 1 million t-shirts come in at an extra 5% 301, but then everything after the first million t-shirts now has a 20% rate or 10% rate, a 12. 5% rate, something else. Um, the mechanism is unclear. It was pretty vague in the announcement and they actually asked for comments on this. So if you have thoughts about how um a textile tariff rate quota system could work. Um feel free to submit the comments you see in the fourth uh the fourth bucket here. Um but it did say that it wants to be proportional to the textile exports that we send to that other country. US is still a pretty big grower of cotton. Most of our cotton though is long staple a little bit higher quality cotton. We still also do polyester, nylon, those sorts of things as well. Um, but we're not exactly the major powerhouse we had been in terms of textile production. Um, much of the developing world has caught up and is probably exceeding what we're able to produce now. So, an interesting dynamic here. Um, but I think if you have a strong opinion about this, there is a little bit of a window to maybe try to influence this process um, via the comment period from the USR. They are receiving these comments through July 6th. There's going to be an in-person hearing on July 7th. And it's just a little bit odd because in theory forced labor or products made with forced labor are banned from the United States. They shouldn't be allowed in at all. They're not allowed entry under any duty rate whatsoever. Um but remember this is more about there's not enough controls in place from some of these countries for forced labor. And that's really the driver of why they're saying this is being done. They're saying these countries are tolerating forced labor. Maybe it's not done exactly in their country, but they turn a blind eye. Their laws are too loose. uh something of that nature. Um many countries disagree with this. Um many countries are saying this is ridiculous USR. We highly disagree. We have very strong protections in place or at least just as strong as yours. Um but that seemed to not be compelling uh to the USR in this case here. So I'm going to leave you with two maps um on this section 301 uh review. And so this is what I showed you a couple months ago if you had seen this. Um those that were in blue were under review for forced labor only. Blue and green were being looked at for both forced labor and um excess over capacity. That second 301 investigation here. Um and you can see here on the next slide where these kind of duty rates are breaking down for all the countries that were blue or green. Those that are in orange have a 10% rate proposed for forced labor investigation, saying that, okay, they haven't done enough to do it or they, you know, they've tolerated it too long or they haven't done enough enforcement on forced labor. Um, and so we're going to propose a 10% rate. And then there's another tier of this 12% rate that would apply to everybody else. And this in theory is more about you don't have any laws on the books. You're really not trying very hard at all. um which includes some odd countries like Norway and New Zealand who maybe don't have quite the same history of forced labor as maybe some of the other countries on this list. But that uh is not exactly what the USR uh has found. They found that these countries maybe are more tolerant of it, more lenient on it um or that they're just uh not being cooperative enough in trying to reduce this. So 10% for those countries in orange, 12 and a half% for those countries uh in blue. Okay, that's our tariff update for today. Thanks for the slight distraction here. Um, and uh, we also have another thing that I couldn't fit into this webinar without kicking out all of CPS-C to talk about the new executive order on foreign importers of record. Spoiler alert, this also impacts regular customs uh, brokers and regular importers as well. So, I'm going to talk a little bit about that. I'm going to have that tomorrow uh, I believe at the same time as this webinar. So, see you in 24 hours to talk about this new executive order on foreign importers of record. But with that, we will get now to the main topic uh of our webinar. Um we will turn this over to my colleague Zach to talk uh consumer product safety. Um and he will uh tell us a little bit more about how to register products, how to be prepared. Only a month away, so we got to make sure our importers are ready to go. — Thanks, Marcus. And thanks to everyone joining on the webinar today. uh you know tariffs in my opinion are so 2025 we're in 2026 right now we're caring about CPSC more um that's half a joke I know all of y'all

are still waiting for your refunds but uh this is also super important for a vast majority of the importers bringing uh items that may be subject to CPSC so a few of my slides here at the beginning if you were on the first webinar are going to be review but we kind of wanted to touch on these uh just so those that couldn't attend or didn't watch have some familiarity or just some basic entry level uh visibility into CPS-C and e- filing and things of that nature. Um I will admittedly say that uh I'm not an expert on everything that's uh subject to CPS-C and required and things of that nature, but uh we'll talk about that more later in the webinar here. We'll start with uh subjectivity. Um, we as a broker have some expertise in certain things. We know, you know, mattresses, uh, toys, things of that nature. Those are all heavily regulated by CPS-C. Uh, there's a good host of resources that CPSC has provided in order for you as the importer to try and identify what goods are subject and what goods are not subject. Some of those are the HTS set and all of these with the underline are linked uh in the slide deck that you can utilize and visit CPS-C's website to do your own kind of back-end research. What we're primarily going to be talking about today is the e- filing website, but we figured this would be a good kind of introduction here. So, uh, CPSC also encourages you to reach out to them directly if there's anything that's a little gray or murky or you're unsure, you know, hey, this is a component, uh, of a certain item that may be subject to CPS-C or it's not subject to CPS-C, but maybe the component might be that's something you're going to want to reach out to CPS-C about directly. Um, it's more concrete guidance than, you know, what we can provide. We can do research as a broker, but ultimately you as the importer have the onus to make sure that CPSC is registered properly and everything uh is handled appropriately before the importation. So, couple links here. I'll skip over to uh something that uh we've kind of introduced. I'll actually go bottom up here. So, uh we have uh updated our ACE analysis. If you're a current Flexport customer or potential prospect, uh we've beefed up our ACE analysis and what this allows us to do is deep dive into your customs information. Uh you give us cross functional access to your ACE account. We pull that data, run it through some of our proprietary uh software that we've created and it will actually tell you which items uh previously have been flagged for CPSC. Keep in mind uh on the brokerage side of things, we have not been filing anything for CPS-C. It's just been I'll call it a soft flag that's been uh getting flagged as you file the entry. So, we file the entry, we see the CPSC under review status. We either get the may proceed or maybe you've had some CPSC exams in the past. That's not uncommon for uh more of the heavily regulated items, but uh in general, this is kind of how it work today. Moving forward, this is going to be more of a broker having to input information and we'll kind of dive into that a little later. But CPSC is also at the top here released uh what we were calling a high risk level HS code list. It's not all-encompassing. CPSC is kind of giving yourself some wiggle room when it comes to giving you the full yes or no on certain items, but it's a good start if you have, you know, your product list up to date. It's worth running through these 600 codes in the additional list on the first slide there. They also have been guiding importers and brokers, those that have been researching to the regulatory robot. Um, everything is going to AI, right? So, why not get the regulatory robot uh in here if you haven't used it? It is fairly intuitive. It'll let you know, you can search by item, things of that nature. And I'll go to the slide here. uh they do preface that it's intended as guidance only. So my from the broker's side, what I would recommend is going through this process if you're unsure. It will spit out actually kind of a results that you can print, save as a PDF, and I would fire that over off to CPSC and see if they can review for you. They might say this is the best guidance that they can provide, but it's worth at least having something from them in writing in regards to the applicability if you're unsure on a certain product. So, you can either search in the search bar there or you can click a specific commodity that you might have and this will help identify if you need a certificate of conformity or a general certificate, things of that nature. So, or the children's product certificate. You might need that as well. You know, most common for toys, things of that nature. Uh, but this is also a good start, a good tool for you to save, bookmark, utilize when you need to. Maybe it's after hours CPSC isn't working. You can

utilize this tool to kind of do some research uh as you wait for their response to your email if you have one pending. So, I found it somewhat handy. I think others that I've talked to, it's been kind of a mixed bag in regards to how uh effective it is, but you know, it's worth giving a shot. And CPSC, if you reach out to them directly the first time, probably will push you to using uh the robot here. So, okay, the product registry, if you have not already registered or signed up for the registry, it's not too late, plenty of time. uh you know we are going to have some mandatory filings for the CPS-C starting on July 8th. So just in time for that holiday weekend. Uh corny joke here, but uh why we want you to uh celebrate the fireworks for the 4th of July and not have fireworks uh when it comes to your supply chain and being uh you know having some issues when it comes to the filings because the brokers will be asking you for this information. So let's uh leave the fireworks in there. All right. So, first slide here is kind of going over how you can register. It's very simple, not like ACE portal. You can click a register now link. And what this will do, uh, what I recommend is at least having someone who plans on being a long tenure person at the company applying or someone maybe in the compliance role uh, at your department that can manage this in the day-to-day. I would have them sign up, maybe use a team email so people can utilize that. that I wouldn't silo it with one individual. You, you know, if you want to take PTO and no one can update the CPS-C information, vacation might be ruined a little bit. So, I would recommend using a team email just kind of keeps, you know, everyone involved that needs to be if you're out of the office or if you leave the company. So, super quick. Uh, certify certifier ID is very important. You're going to want to pick something that's specific to your company. So, if I was doing this today, I'd put Zack Clawson LLC or ZC LLC just to identify uh who I am, that'll be important as the brokers go to file the entry. So, keep that in mind. You don't want to put something random like, I don't know, best broker ever, 2019, something like that, something that's more applicable to your business. So, these are some of the roles and responsibilities that you'll find on the e- filing website. Uh, so there's the business administrator, collection editor, and viewer. From a brokerage perspective, I've been advising clients to add us as the viewer. We don't need to be the collection editor, administrator, or even the business administrator. We can't create the account for you. Viewership is fine for us as brokers. We will have access to your e-iling website. It's almost like cross access to your ACE account if you've given that to your broker. So, anytime you input a new product into the registry, we'll have access to that. You do have to give us viewer permissions. So, if you have, you know, five different collections that you create. We need five different emails sent for each collection. There's, as far as I've seen, not an all-encompassing one that you can send. I'll double check that, but usually what we've received is the links to each specific product collection. Um, and when it comes to the collection administrators or editor roles, the importer can have the suppliers added as those roles as well. So if you want a supplier or a manufacturer to have access to your e- filing to upload the information, that's totally okay. It might be recommended for some too as the manufacturers or suppliers usually have more insight maybe into the testing that's been done on the products. Totally okay, fine, and acceptable. It's really what permission you want to grant to individuals um because they will have access to this data they will be able to edit if something goes wrong on the entry filing or if someone accidentally you know fat fingers some information u that will affect the e filing but if you're comfortable giving those permissions uh to your suppliers or manufacturers then by all means do it if it takes uh you know some work off of your load there. business administrator. As I mentioned before, you want someone uh that's really going to be long-term at the company. You don't want a junior specialist or intern as the B business administrator. No offense to the business uh or the interns out there or anything like that, but you want someone that kind of has uh a longstanding time at the company. So, in case things go ary or if CPSC needs to reach out to somebody, you can have that person as the point of contact. Um ultimately this the onus of the CPS-CE e filing does fall on the importer. CPS-C has made that very clear and again it's up to you and your discretion on how much visibility you want to give to other parties. So all of these screenshots this screenshot here is directly from a uh CPSC guide. CPSC's done a great job in I

would say gathering all their information. There's a handy link uh I will put it in the chat here at the end uh that lists all of kind of a timeline of events from like the beta pilot all the way up to present day information where you can watch uh videos or get templates on how to do things or user guides. Some of them are lengthy but you know this is very new process for everybody. So they want to make they wanted to make sure that everything was very detailed and uh the ease of access for everyone to have the information. Um, they have a set of YouTube videos as well, which I've watched a few times, and those are pretty handy, especially when it comes to you first getting your login and adding prof or adding items to your profile or your e-iling platform, things like that, your product collections. The videos are very handy when it comes to doing that. Okay, there's two ways that you can register the products. There's a bulk upload which is a big CSV template linked here. It's also on CPSC's website. If you're a major importer that has a lot of items flagged for CPS-C, this might be the route you want to go rather than a one by one upload. That's going to take someone a lot of time. Uh the fields, you know, will show you what's required, what's not required as you upload uh the bulk. And what will happen and we'll kind of see this as I do the live demo here is the CPSC's website will show you what uh turns out that you need to fix and what is actually valid on the website. So it's less time consuming. Uh you can't change the format of the fields. There is a user guide uh that they provide in regards to how CPSC wants the data structured on the bulk upload template itself. um it is a little particular I'd say. Sometimes they don't want commas in certain cells and things like that. So you want to make sure that your data uh is extremely detailed but not overly detailed. That would cause an error on the actual form itself. So here's kind of what it looks like as you go to do the bulk uploads. There's four steps here. I won't spend too much time on this slide because we are going to do the live demo here momentarily. Um but you'll have the slides here in case you want to view and then you can also as I mentioned uh CPSC does have a YouTube video that you can watch on how to do this. So as soon when you have the successful uploads for the bulk uh what will happen is the products uh will become visible almost instantly on the platform if you've done everything right. Uh there is a 48 hour grace period for you to edit the information. If maybe you realize you copied down a cell the wrong way or things like that and you want to make sure that information is right, you can go back in there and edit it. Uh you can also bulk export out of the product registry, which is nice. So maybe you don't want to give your broker uh viewer access to your eiling. That's totally understandable. It's your supply chain, your information, your data. What you can do is export the data and send it uh in a CSV or an Excel file to your broker and they should be able to file the entries with that information. Um the purpose of essentially uploading this information into the CPSC filing is so that uh you get a reference message set. Um, I'll talk more about that in a bit as we progress through here, but that's going to be super important for those that are heavily uh affected by these changes here. Um, the singular single manual uploads exactly what it is. It's more manual. You're having to go in to the website. Each field you're having to enter, as you can kind of see uh in the GIF here, this is what we're going to walk through here in a few moments. But, uh, if you're a smaller importer, maybe you have two or three items that, uh, or maybe 10 that are subject to CPS-C, this might be easier than trying to go in and do the bulk upload. Um, especially if you have one supplier, it's fairly quick to just go in here and kind of add them. Uh, you can save products, uh, which is a nice feature. If they're incomplete, you can still save them as an in progress. So, you can come back, edit those. maybe you're missing what skew you want to use or maybe you're missing the testing laboratory, things like that. You have that ability so you're not uh just doing these things and then losing all of your data in case you step away from the computer, get called into a meeting or things like that. So, okay, I am going to stop sharing. Fortunately, you're going to have to stare at me for a second and I will reshare. Let's go through the live demo here. Let me get situated. And we are collecting questions in the chat. So if you have those questions, feel free to shoot those over and let's get started here.

All right. Okay. We're going to go this is our kind of compliance login here. We're going to go to the webinar test. We're going through the singular upload now. Uh, and so here I'll kind of talk about these little blocks that you can utilize. We can manage users here. So, Callum here works at Flexport. If you haven't met him, great guy. Uh, we can also invite other account administrators here. We can invite users. This is where uh you can invite your broker or maybe they're just the freighter or your supplier or whoever you want to give these permissions to. You can invite the user. You type in their email. uh you give them what collection they want and then you give them the viewership access level that you want. So this is kind of like the premium access, mid tier, and then lowest tier. And again, I recommend the viewer as for the brokers when you're sending this out. We don't necess we are not going to edit any of your information on the brokerage side or upload anything for you. We don't want that liability to be honest. So just be sure that you're giving viewership. We'll go back here. Um and that should suffice for the brokers. Uh you can also invite from this. So if you want to invite a user, again, same rules. It's a simple platform, not too many things to, you know, click on or add or anything like that. But here we'll kind of run through a product. So we're going to say this is Zach Pickle Jumper. My last name is Clawson. I candidly don't know if I have any uh stake in the Clawsome pickle empire, but if you're out there and listening to this webinar, please let me know. I would love to uh get in on that. So, we'll do product one, two, three. Let's add a four here. Um there's a dropown. Anything you see with the star, you're going to want to add. Okay, those are going to be the mandatory fields there. Manufacturer name, we'll do pickle creations. If you have to add a new one, what happens is you just create a manufacturer. And just for time purposes, I won't fill in all this information. Um, but you go in here, add the manufacturer, and again, suppliers, manufacturers can do this on your behalf if you've given them the correct permissions. So, we'll go at pickle creations. We'll say we manufactured this item last month. Okay. Hit next. And we'll say, you know, you have the two types here. You have the general certificate of conformity. You have the children's product certificate. We'll use GCC. And we'll say the last test date was 052026. Sometimes this gets a little particular. Make sure you put your slashes in here just as it says. Um, what's nice here is if you know that your laboratory that's doing the testing is CPSC accepted, you can click here and search through the name. You can type, you know, and show results, things like that. Or you can just do other if it's not CPSC accepted. accepted, that's okay. CPSC has stated on their website that it doesn't necessarily have to be a CPS-C accepted testing site. It's probably more of a preferred one just because they have all the information of the laboratory, but it's not a requirement. So, for the sake of this, we're we'll check CMA Industrial Hong Kong. There are some other things down here. You can add citations. So, let's say you search for toys and you know there's the squeeze toys, battery operated toys. We'll say this is a battery operated toy. You should be able to add more than one if you need to. if it falls under more than one regulation. For the sake of this, we'll leave it at the one. Uh you can also add an additional laboratory component part testing. If your component is subject to CPS-C, you're going to want to mark this. Additionally, they have a testing exclusion. So, you can click this and it will create another box here. So, if you know that your item does fall under a testing exclusion, you can scroll through here and pick which testing exclusion is applicable to your items. So, I haven't tried searching this yet here, but it looks like you can also type a word. So, you can also see where some are inactive. Okay, maybe these have been removed and are no longer valid. But we have here uh exemptions for straps used for waist restraints on ride on toys are exempt from the free length and loop requirements. Okay, we will not deal with that today, but just wanted to show that as something that's available here. Once you click next here, it will take you to this screen. If you have two checks at the top here, that means you're doing a great job. If you're missing information, you'll have an exclamation mark that will make you

um go back and revisit the information. So, let's say I forgot this. Let me go next. We'll have the field here that says, "Oh, hey, we're missing some data here. We should probably go back and check. " And then you'll have the red box here that shows that you're missing your citation. So, we'll find our citation again. We'll go with battery operated. And here if you click generate version, this will give you your version ID. Uh point of contact, importer, manufacturer, laboratory, broker. I don't imagine for the most part this will be broker. For the sake of this will be importer since we're acting as importer here. You'll go ahead and hit certify. And it'll say your product has been saved successfully. And there we have it. Zach Pickle Chomper is now an active product. Uh once you click on it here, it will expand and then this will provide the data that you can send to your broker as they go to file the CPSC information. So what the broker is going to need if they're doing the reference message set, um they'll essentially need three items, four actually. They'll need the product ID. They'll need your version ID here. There it goes because I clicked on it. Sorry about that. Version ID here. They'll need an intended use code, which you can find in the CPSC uh or the Cater that goes over the CPSC. There aren't too many to choose from. We're not in FDA medical device territory here. We're just uh in the CPSC. So, I would say only a handful, I believe. Maybe less than 10. I might be wrong there, but there aren't too many to choose from, and most of the ones that are going to be used are the consumer product uh ones. So, essentially, what you can do if you have messed something up, you can also create a new version, you can edit, you can archive, you can export to PDF. So, you can send this off to your broker. They'll have the data uh so that they can go in and file this through ACE as they are filing their entries. So, that is the singular upload. Uh you can also do this export here. If you want to export the CPS-C, send it off to your broker uh CSV, sorry. broker. They can save that uh in their documents and not have to bother you when it comes to the entry filing itself. So um I do see we're running a little short on time, so I'm going to kind of expedite the bulk upload here. If you want to do a bulk upload, again, there's a CSV template on CPSC's website. I have a pre-saved one here. you open it, you can see that there's kind of zero new product entries, right for import, zero new. So, it'll kind of read the data. Candidly, I didn't do a great job of filling out the data, but this we kind of just wanted to give a highle overview here of what you might see as you go through here. So, uh, so we have three new product with entry errors, things like that. You can kind of hover over these and see, you know, maybe what is the error, things like that. Um and I will post actually here in guide of items that CPSC has provided. This is going to be posted in the chat that you can view and kind of scroll through and just make sure that your formatting is aligned for how you want it to be. So, that was pretty quick on the bulk upload. I know some of you might have thousands of items that you're uploading there, but I just wanted to give you all a quick glance into what that looked like. So, um, for now, you know, I think what we'll do is go to Q& A. I imagine some people have some questions. Again, some of the items that you might want regulatory questions on, we would guide those to CPSC. We just don't want to give you the wrong information right now without doing some back-end research. So, appreciate everyone's time. Um, we also have a few resources here at the end. I will switch back one moment that we will share. I mentioned the ACE analysis earlier. It's a big part of what we do here at Flexport. Super handy. We've got some links here. Testing HS codes. Kind of already talked about those. ACE analysis. If you want to see what's affected by uh what you're already importing that's affected, contact our team here and we're happy to do that. This is a free service that we provide. It will help you get some good insights into everyone's everyone has ACE now, right? Like we all got our portals because we want our refunds. So now uh what we can do is really dive deep into your data and the details and get you maybe you miss some savings or maybe you just want to see what's affected by CPSC. can do that using the ACE analysis. So, uh we have our team emails

here on the right. If you have some inquiries, uh feel free to reach out to us. And with that, we will move to Q& A. — All right. Very, very helpful here, Zach. Um very good. So, I guess, you know, I think I kind of have two questions here um that are a little more general, but I think are valuable. Like how responsive has CPSC been in that email handle? Like when importers reach out, are they getting pretty quick replies? Are they getting help? Is CPS-C doing a good job preparing importers, would you say? — Yeah, I would say compared to customs. Yeah. Uh they have gotten back to me sometimes. I think the longest I've had to wait was maybe 5 days, but I the normal turnaround time I've seen has actually been around 48 hours. Uh now I'm not asking the most intricate questions that an importer might ask, but [clears throat] yeah, for the most part they are very quick to turn around because they want this to be as seamless as possible. — Okay. And what would you kind of say is maybe like the time commitment? I thought this was a good question. What does like the time commitment look like for registering products? You just kind of did a demo here. Seemed like that was about like 8 to 10 minutes for one doing it manually. Um what you know kind of what based on your experience, what have you seen as like kind of the time commitment for that? Yeah, I would say probably 5 to 10 minutes per product, but you're also going to, if you're doing the singular, you're also going to get more experience and how to navigate the fields. That first one, like everything you do is going to be a little more lengthy, but as you get more familiar with the actual website itself, it becomes fairly quick. Uh, it did take me, you know, a few minutes to get to it, but I would say around 5 to 10 minutes. — Okay. All right. Um, well, I have a couple of questions here that I got for um, some 301232. I'm going to just kind of go through those a little bit quick here. Let Zach get a drink of water. Um, where can I find information on the HTS that are being considered in the initial scope for section 301. Um, this is not necessarily an HTS list as it is every product unless it's exempted. So, this is um, everything from that country. If the country of origin is uh you know is X um then the 301 would apply. So it is every HTS um with some exceptions um for some of the categories that I mentioned chemicals a lot of chemicals are exempted a lot of pharmaceuticals are exempted civil aircraft parts exempted critical ores and minerals um produce that we can't grow in the US or grow in any kind of commercial quantities um and beef. Um, if you heard my webinars before, you know I say health care, housing, gas, and groceries are how the president seems to make decisions for exemptions. Um, beef herd is at the lowest in 75 years in the US. So, um, we're seeing some discounts there. So, it is every product on just a list of HTS codes. Um, uh, I would say though on that there is, um, you know, if you did want to see that full list of exemptions, um, let me find, uh, I will send it in the chat in just a moment here. Um, but the USR did have about 70 pages of the HTS codes that they're planning to exempt. Um, and I can add that list uh to the chat uh just for reference. Um, are US entities able to submit comments for the 301 proposal or can international do this as well? It can be both. It can be international or US uh or US entities. Um, what's your expectation on stacking 301 force labor and 301 over capacity? Do I think they'll go into effect before the overcapacity or both go live at the same time? Forced labor I am expecting to go into effect on July 24th or before. Um that's when section 122, that 10% um you know balance of trade tariff uh expires. It expires after 150 days and that 150 day mark is July 24th. Um this forced labor timeline seems to be right on the edge. It seems like it might be it could be going live right around the time that does expire. So, I think that's probably their intention. Um, and they look to be on schedule uh to that effect. I do expect it to stack. Um, I do expect those two things to stack on top of each other. And yes, I do think uh somebody asked about that. Is the section 31 going to stack on the 10% today? No, I don't think so. I think 122 is going to expire. I don't think it's going to stick around after the 24th. I don't. You know, in order to stick around, Congress would have to reauthorize it. And I don't think this is the Congress to do it, especially in an election year, especially when inflation is still a little bit sticky and hard to control. I don't think they want to be seen as taking a vote to increase taxes on Americans just a couple months before election. So, um let's take a look though at maybe a couple of these um CPSC questions here um for you, Zach. Um let's see, we have one. — I think I can group some together. Um, [clears throat] I just posted requirements for GCC and the children's product certificate as well. If you want

to bookmark those, that'll be helpful. Um, let's see. What contact details are we adding a viewer for our broker? Um, you would essentially send it to We're utilizing our team email here. So my team has a team email where all the folks uh who file entries on my team, we have access to that. So very similar to how you register using a team email, we're doing that as well. And that's something I would recommend just so you know, all the brokers have visibility. You're not relying on one person who might be your day-to-day filer. Well, if they're on vacation, then you know, you're going to be kind of in some trouble there. Um, but yes, I would recommend that. Um, importer uploads into CPSC, not the US agent. Correct. As an importer, you want to upload or you can have your supplier or your manufacturer do it. We kind of talked about that at the top. The broker won't have the details here. You might be sending them a GCC or children's product certificate, but again, the onus is on you as an importer. If they put information in there that's incorrect, that's going to come back to you as the importer. So, please keep that in mind. Um, maybe one or two more here. — Yeah, Zach, I see one here. — Yeah, go ahead. — Yeah, I see one that I think I've seen a few different flavors of this question here. We have a product that has different colors and different sizes, but the product is ultimately the same. Do we have to do an e filing for every single skew or can we do it by style number? — Uh, you should be able to do it by style number as far as I understand. I can definitely double check that. might take me a second. I believe I've asked that before. — Yeah, I think that's what I call two here as well. Yep. — Uh let me pick or you [clears throat] find one and we can jump from there. — Yeah. Um how can we bulk claim dis or I'm sorry. How can we bulk disclaim products? Is this something that uh is allowed? gets supported in there? And I don't I think the answer is no, right? Let's see. I have the bulk upload template here and I don't see that there is a disclaime which leads me to believe that that's a no. — Yeah, I think I think for that you know we're these are registering products that are subject you know to these rules. So they would probably have their certificate testing requirement that sort of thing. So if it doesn't need to be registered I don't think they want it. I think the question if you have like a lot of disclaims to do that's probably something that needs to get provided maybe in bulk by skew or item number to your customs broker they can save it in their API system flexport we can save that in our own product library so we can save those disc claims um and the intended use codes for them um I'm sure many other customs brokers are similar in that respect um let's see how about duplicates how do they uh how do We deal with duplicates in there. If somebody, you know, you have multiple, you know, everybody's trying to get it done here before it gets done, right? We have the skew added once. Is there any kind of warning if it if a duplicate product is added? — Yes, you should get a warning saying that the product already exists. Um, but yeah, they don't want multiple items of information in there. I think that would just cause confusion for everybody. So, yes, you should get a I can't remember the exact message, but you should get a warning saying that item's already added or you'll get an error if you do the bulk upload that as I showed in the webinar, you'll get kind of the red font showing what you need to fix. — Okay. Um, I have another one I think is pretty key here as well. Um, we have uh let's see, we see that there's a difference between the reference message set and a full message set. Uh, can you just briefly talk about the difference between the two? Why would I use one over the other? — One was going to be cost. I imagine uh brokerages are going to charge you more if you're doing the full reference message set. It's more work on their side. They're going to have to manually input all the fields from your certificates into ACE as they file the entries. Whereas a reference message set, if you have that preloaded onto the product registry, we're simply adding four fields into our filing software in order to file. So it should be cheaper for you uh and also less timeconuming for the broker. So you want your goods quickly cleared, right? You don't want them sitting at the port. So the easiest way for that to happen is getting the information on the registry sooner and getting it to your broker uh so that they only have to do the message set reference message set. — So what we saw today in the demo, you know, in the CPS-C portal is you added all of these data elements in there together, right? Color, skew number, description, manufacturer, all that. And so what you're saying is that they can either kind of add it up front and generate that reference number or they

can just kind of give the certificate to the broker and then the broker has to go recreate that at the time of entry. Is that the difference? Yeah, — correct. Yes. — Okay. — Now, if you're importing one or two products, it might not be worth signing up for the e filing to be honest with you. You can just send the broker their information. But if you are heavily impacted by the changes here, you're going to want to do the reference message set because it's going to save you time uh when it comes to the filing and maybe even demmerge or storage at the port as you run into delays. So keep that in mind. Um before I before we move on, and I know we're kind of over time here. Uh I wanted to go back to the color question uh because I did ask CPSC this. So I'm just going to read verbatim what they told me. Um they said importers may not enter product certificate data for multiple similar products into a single certificate but must create a separate unique certificate for each product. Even though CPS-C considers apparel items from the same material with multiple styles, sizes and colors to be one product if the items were manufactured and tested together. CPSC considers two products unique if there has been a material change such as design, manufacturing process or source of components. Even like models with different colors could be considered unique products and therefore would require separate certificates. Even if both items are under the same product ID, you could still use the same product ID but use different version IDs to differentiate the certificates. So to me that says you need — can have the same product ID different version ID. So there is a small tweak. You'll have — two different sets of data that you'll want to send to the broker based on the color. — Okay. But as I as our call though just to kind of you know take down the blood pressure of any apparel importers on here, there is kind of some enforcement discretion happening right now on the part of CPSC for like requiring this registration for adult clothing. Is that your understanding as well, Zach? — Correct. Um, — yeah. — Yeah, it's it's a little murky right now on some I think if you have a question that you're unsure of, reach out to CP. We'll first start with the regulatory robot because they're going to send you that way. uh but then go to CPSC directly and like they've given me here, they'll they try to be pretty direct when it comes to the communication because they don't want any issues on their end or cause any delays once the goods hit the port. So — yeah, I think what we can at least say from our side though is that the CPSC flags that we're seeing in ACE and our, you know, the customs filing system, a lot of that adult perilous flagging is optional. So that may mean you do have to report something, but as Zach pointed out, make sure your CPS-C agrees with your understanding before kind of saying which way to go on it. Do you want to claim it or disclaim it um or not? But it is the case that for a lot of the children's apparel, um children's sleepwear, those do seem to have a little bit more of the required flags, even though most like adult apparel, even if it flags for it, isn't necessarily mandating that you have to submit some of this information. So that's kind of maybe an important distinction here is that there could still be some disclaimers allowed, but even the disclaims I think I just want to call this out as we look at the message set for CPSC is that the disclaimers aren't as easy as other PGA. If you're like, "Oh yeah, I've done TUSA before. " disclaimed FDA before. " That's just kind of an indicator that the broker says it's kind of a yes no um indicator. But here it's saying, "I'm disclaiming it. " You have to give a reason. an intended use code as well. So that makes these disclaims a little bit harder than most other PGA. Other PGAS if you disclaim something. Um then it's just that's kind of the end of it. Here you had to provide a little bit more information. Maybe that's why we had that question about can I bulk upload disclaims into CPS-C system. Right. That was a good question from them. Um well we are uh over by a little bit here and I think we're going to call it um a day. Um, thanks very much for everybody, your attendance here, all the questions. Um, we'll send out an email with a link to a recording tomorrow. Um, have a great rest of your day. I hope to see you tomorrow, um, for the webinar on foreign importers of record after this new executive order. But thanks everybody. Take care. — Thank you.