Jarden Corporation – 2014 Customs & Trade Question

Jarden Corporation – 2014 Customs & Trade Questionnaire

This questionnaire serves to obtain a more in-depth view of the import and export activities at your facility. The results of this questionnaire will help Jarden Corporate in conjunction with the Business Units determine areas of opportunity in our global import/export operations pertaining to compliance, operational efficiencies and whether Jarden and its businesses should be exploring software tools and developing best practices to help manage our complex trade network.
The questionnaire will refer to “Customs and Trade.” For purposes of this study Customs and Trade is defined as:
Activities related to interaction with government regulatory agencies that monitor cross border trade, i.e., importation and exportation. This can include, but is not limited to: All Customs, Other Government Departments (OGD) compliance and strategic activities. Communications with customs, OGD authorities, customs broker/agent management, documentation retention, internal audits, custom’s and process development, and related activities.

Important:

Facilities: A facility can be a factory or distribution center that imports and exports. If your responsibilities cover import and export for multiple facilities, we ask that you submit a separate reply for each facility you manage. A consolidated questionnaire can be completed if your import and export program is the same across the facilities you manage, providing those facilities are all in the same country. The questionnaire will reference “facility” in the singular, we understand you may be responding for multiple “facilities”.

Who should complete this questionnaire? The person responsible for import and export or other cross border regulatory requirements should complete this questionnaire. We understand that multiple people may assist managing customs and trade functions and will be required to participate in completing this questionnaire. For purposes of defining ownership, list the lead individual responsible for compiling response to this questionnaire as main contact below. At your discretion you can list other individuals who assisted you in completing this questionnaire, at the end of the report.
Please attempt to answer all questions to the best of your ability and return the completed questionnaire by February 21, 2014

1. In any instance where "Other" is selected, an explanation must be given in the “Remarks” section following the question. Feel free to use the “Remarks” section for any elaboration of your response.
2. If a question does not relate to your facility, note “Not Applicable” in “Remarks” section with a brief explanation why.
3. For some questions, multiple responses are accepted. These questions will contain, "Select all that apply."
4. If additional space is needed for your responses, please use the “Additional Information/Comments” field at the end of the survey.

We understand that the business model employed at your facility may be complex and make it difficult to respond conclusively to some of the questions. If you need assistance responding to a question direct all inquiries to the customs and trade lead at your company’s headquarters to help you determine best way to respond.
The Customs and Trade lead for your company will be on the email that contained the link for this questionnaire.

Thank you for your cooperation and time.

Sincerely,
Frank Garcia
Jarden Director of Customs and Trade

Questionnaire Contact Information


* Company/Business Unit:

* Facility Name(s): (Optional)

* Facility Address(s):

* Country:

* Main Contact Name:

* Position/Title:

* Email:

Entity – General Organizational Information

In this section the intent is to gain an understanding of your facility and the individuals and resources devoted to managing customs and trade functions.

Please note - Based on your response, you may skip certain questions in the survey.

a. Name of Business Unit?

b. Country facility resides in?

c. The region the facility resides?

1. As the primary person responsible for Customs (import/export) matters, who do you directly report to within your organization (for example, Director of Supply Chain, VP of Accounting, etc.)

1a. Where does the Customs function reside?

Finance

Operations

Supply Chain

Other

2. Do you focus strictly on Customs and Trade or do you have other responsibilities? List below your responsibilities. Select all that apply.

a.Customs and Trade

b. Logistics/Transportation

c. Distribution

d. Procurement/Sourcing

e. Other Supply Chain

f. Finance/Accounting

g. Other

Remarks: (Must complete if “Other” was selected)

3. Are there others that report to you that support Customs and Trade function

a.Yes

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

4. Approximately how many hours total per week is dedicated to Customs and Trade function at your facility or facilities under your management? (Facilities you are completing this questionnaire for)

4b - Approximately how many hours total per week is dedicated to Customs and Trade function at your facility or facilities under your management?

5. Have individuals responsible for Customs and Trade function received training? Hold certificates or licenses? Select all that apply.

a.Yes, received training. Explain in “Remarks”

b.Yes, received license or accreditation. Explain in “Remarks”

c.No training

d.No, learned through experience

e.Other

Remarks: (Must complete if “Other” was selected)

6. Describe the functions impacted by customs and trade that are performed by your facility. Select all that apply.

a.Imports Finished Goods

b.Exports Finished Goods

c.Imports Raw Materials

d.Exports Raw Materials

e. Manufacturer for domestic consumption

f.Manufacturer for export only

g.Manufacturer for domestic consumption and export

h. Other

Remarks: (Must complete if “Other” was selected)

7. Do you use any of the following special economic zones, regimes, licenses or schemes? Select all that apply.

a.Foreign or Free Trade Zones (FTZ)/Zonas Francas

b.Export Processing Zones (EPZ)

c.Bonded Logistics Parks (BLP) or Customs Warehouses (CW)

d.Cross-Border Industrial Zones (CBIZ)

e.Integrated Free Trade Zones (IFTZ)

f.Bonded Ports (BP)

g. None of the above

h.Other special economic zones, regimes, licenses or schemes that result in customs duty benefits and efficiencies?

Remarks: (Must complete if “Other” was selected)

8. Indicate any other trade customs programs that the Company utilizes to reduce its duty liability. Select all that apply.

Remarks: (Must complete if “Other” was selected)

9. What ERP system does your facility use?

9a. What ERP System does your facility use?

10. Does your facility participate in a security program: C-TPAT, PIP, AEO, etc? If so, indicate which one.

a.Yes we participate in a security program. Note in “Remarks” which program.

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

11. Related to the management of your facility, which of the following summarizes best the business model. Select all that apply.

In this question we are attempting to learn if there is collaborative relationship with a sister company, and the nature of that relationship.

a.We manage our facilities operations, with our own employees.

b.We manage our facilities operations and operate in the capacity as a “Distributor” for another Jarden sister company. Note, in “Remarks” the Jarden sister company. [Distributor Definition: A distributor buys your goods from you and then takes full responsibility for selling them in your local market.]

c.We manage our facilities operations and also manage operations for another Jarden sister company, similar to a third-party logistics provider (3PL). Note, in “Remarks” the Jarden sister company. [Definition 3PL: A third-party logistics provider is a firm that provides service to its customers of outsourced logistics services for part, or all of their supply chain management functions. A 3PL does not take ownership of the goods.]

d.Our sister company manages the facilities operations and operate in the capacity as a “Distributor” for us. Note, in “Remarks” the Jarden sister company. [Distributor Definition: A distributor buys your goods from you and then takes full responsibility for selling them in your local market.]

e.Our sister company manages the facilities operations on our behalf, acting in capacity similar to a 3PL.

Note, in “Remarks” the Jarden sister company. [Definition 3PL: A third-party logistics provider is a firm that provides service to its customers of outsourced logistics services for part, or all of their supply chain management functions. A 3PL does not take ownership of the goods.]

f.We use an unrelated 3PL, who manages our facilities operations.

g.Other

Remarks

12. If you indicated in 11 that you and a sister company act together as either a distributor or 3PL, confirm if this questionnaire provides responses for a single entity or both entities combined.

a.Questionnaire responses are for single entity, noted in “Remarks” below.

b.Questionnaire responses are for multiple sister companies, noted in “Remarks” below.

c.Other

Remarks (Must complete if “Other” was selected)

Custom Agent/Broker/Representative Management - Imports

In this section the intent is to understand the relationship and controls in place between your facility and the company that submits customs declarations (entries) to the customs authorities on your behalf.
Definitions:

Customs Agent: Depending where in the world you reside, this company may be called either a “Customs Agent”, “Customs Broker” or “Customs Representative” For purposes of this questionnaire we will refer to them as “Customs Representatives”.

Declarations: Depending where in the world you reside, the submissions for release on either imports or exports may be called either “declarations” or “entries”. For purposes of this questionnaire we will refer to them as “declarations”.

13. Does your company self file customs declarations directly with Customs and does not use a Customs representative?

a.Yes, 100% of our entries are self filed with Customs

b.Yes, we self file entries with Customs, but also work with a Customs representative on some of our declarations. If this is the case, indicate in “Remarks” the approximate percentage of self-filed entries.

c.No, we do not self file entries

Remarks:

14. Describe the relationship your facility has with the service provider that performs the customs declaration process.

a.The service provider extends to us freight forwarding services and they are the licensed representative that performs the customs declaration/clearance process.

b.The service provider extends to us freight forwarding services and they nominate a 3rd party company that performs the customs declaration/clearance process.

c.The service provider extends to us only customs declaration/clearance process services. We have another company that provides freight forwarding services

d.Other

Remarks: (Must complete if “Other” was selected)

15. Indicate the top 5 customs representatives your facility utilizes (Not Freight Forwarders).

	Customs Representative Name	Main Contact	Phone Number	% of Import Business Managed (by Value)
1

2

3

4

5

16. Do you track customs representatives’ performance?

a.Yes (If “yes”, explain briefly in Remarks)

b.No

c. other

Remarks (Must complete if “Other” was selected)

17. Does your facility have a documented operational agreement with the customs representative specifying the parameters in which they are to conduct business on your behalf, i.e., Memorandum of Understanding, Standard Operating Procedure, etc?

a.Yes

b.No

c.Other

Remarks (Must complete if “Other” was selected)

18. Does your customs representative act as a direct or indirect representative? .

Definition: In the case of direct representation, the customs representative acts in the name of and on behalf of your company. In the case of indirect representation, the customs representative imports under the representatives name but on behalf of your company

a.Direct

b.Indirect

c.Both

d.Other

Remarks (Must complete if “Other” was selected)

19. Does your facility provide the customs representative with a listing or database of all imported items, i.e., skus, part numbers, etc, along with relevant import/export data elements (for example, customs commodity code, HTS, product descriptions, preferential trade agreement eligibility, etc)?

a.Yes

b.No

c.Other

Remarks (Must complete if “Other” was selected)

20. If “yes” to 19, how often is the listing or database sent to the customs representative?

Remarks: (Must complete if “Other” was selected)

21. How are commercial invoices, bills of lading, etc., sent to the customs representative? Select all that apply.

a. Via Electronic Data Interface (EDI), spreadsheet, delimited file (format that allows for electronic upload into the representative’s system). Explain in “Remarks”

b. Via PDF, Imaged File (format that does not allow for electronic upload into the representative’s system).

c. Hardcopies sent via courier/post

d. Other

Remarks: (Must complete if “Other” was selected)

22. How long does your facility retain Customs import records?

a.0 through 4 years

b.5 years

c.6+ years

d.We do not maintain records, our customs representative maintains on our behalf

e.Neither our customs representative or our facility maintains customs records.

f.Other

Remarks: (Must complete if “Other” was selected)

23.Does the Company conduct a post entry review (audit) of customs declarations for accuracy after it was submitted to customs?

Yes

Other

Remarks: (Must complete if “Other” was selected)

24. Approximately what % of declarations are audited?

Remarks: (Must complete if “Other” was selected)

In this section the intent is to understand the process at your facility for reviewing a new product and determining the Harmonized Schedule (HS). Hence forth we will refer to this process as “classification”. In this section we will also ask questions inquiring what other trade related information is ascertained during the classification process, i.e., free trade eligibility, anti-dumping, export controls, etc. Our goal:

Determine if we have the right expertise determining classification;

Determine if we have redundancy of effort with different facilities among a single business unit classifying the same product, with no sharing of information among the facilities;

Determine if we should have better tools to manage our classification programs.

Both importation and exportation require information to be gathered about a product during the classification process. Some business units will classify for import and export at the same time. Some BUs classify for imports and exports separately. We will look to understand your classification process for both import and export in this section.

25. Are products classified for import and export at same time in process and by same team/individuals?
This is the question that will help us understand if you have a separate process for classifying import and export.

a. Yes - same time in process and by same team/individuals?

b. No – Same time in process, but different team/individuals

c. No – Different time in process, but same team/individuals

d. No – Different time in process, and different team/individuals

e. No – Classify import only, we have no process for classifying export

f. Other

Remarks: (Must complete if “Other” was selected)

26. Where does the central repository for tariff classification information and other pertinent customs data reside? (Select all that apply)

a.Spreadsheet

b.Database (in-house developed)

c.3rd Party Customs and Trade Software Package (Global Trade Management – GTM)

d.ERP system

e.Other

Remarks: (Must complete if “Other” was selected)

27. At what point in the process does your facility classify its products?

a.When the part is set up

b.Prior to purchase orders being issued to vendor/manufacturer

c.Prior to product shipping from vendor/manufacturer

d.Prior to products arrival at the destination port

e.When the goods arrive at the destination port and shipment being prepared for customs clearance

f.Other

Remarks: (Must complete if “Other” was selected)

28. Describe the approach and responsibility for classification at your facility. Select all that apply.

a.Our facility internally classifies our products

b.The customs representative classifies our product

c.The freight forwarder classifies our product

d.Our facility in conjunction with our customs representative classify our product

e.Our US or EU headquarters classifies our product

f.Our facility in conjunction with our US or EU headquarters classify our product

g.We use a 3rd party to classify our products. If this is the case, explain in other, who this party is.

h.The vendor/manufacturer informs us of the classification.

i.Other

Remarks: (Must complete if “Other” was selected)

29. Are all new product classifications reviewed and verified for accuracy by a second individual prior to them being utilized? If so, explain in “Remarks” who that individual is.

a.Yes

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

30. If your facility classifies product internally, explain the individual or team’s training to classify

a.Have received formalized training. If so, describe in “Remarks” that training.

b.Have learned through experience. If so, describe in “Remarks” that experience.

c.Have not received training, but it is just common sense, we look through the book for the closest HS code.

d.Other

Remarks: (Must complete if “Other” was selected)

31. Describe the materials utilized to classify the product. Select all that apply.

a.Product Specifications

b.Product Drawings / Pictures

c.Bill of Materials (BOM)

d.Marketing Materials

e.Product Samples

f.Base strictly on the product description in our internal systems

g.Base strictly on the product description on the commercial invoice

h. Other

Remarks: (Must complete if “Other” was selected)

32. Classification Recordkeeping: Is the support for how the classification was determined (for example, product specifications, customs rulings, General Rules of Interpretation, etc.) retained in a centralized database or management system?

a.Yes

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

33. Has the Company obtained Binding Tariff Information (“BTI’s” or customs rulings) from Customs authorities on any of the Company’s products?

a.Yes

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

34. Does your facility review and validate a product’s eligibility for a duty preference or Free Trade Agreement when classifying a product? If “Yes” briefly describe in “Remarks” that process.

a.Yes

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

35. Does your facility review a product to determine if the product is subject to “Other Government Agencies/Departments” at the time the product is being classified? If you products are subject to “Other Government Agencies/Departments”, list them in “Remarks”

a.Yes

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

36. Does your facility determine if the product is subject to punitive duties, i.e., Antidumping when the product is classified?

a.Yes

b.No

c.Other

Remarks: (Must complete if “Other” was selected)

37. Does your facility review a product to determine if export controls apply at the time the product is being classified for import? Select all that apply. More questions on “Export” will be asked in the “Export” section.

a.We assign the Export Harmonized Schedule, i.e., Schedule B Nbr

b.We assign the Export Control Classification Number (ECCN) (EU General Export Authorisations in European Union.)

c.We determine if product requires an Export License

d.We determine the admissibility of the product in the country of ultimate destination

e.Not Applicable – As noted in question 25, we classify for import and export separately.

f.Other

Remarks: (Must complete if “Other” was selected)

Export

In this section the intent is to understand the export process at your facility, both from an Export Control and operations perspective. We also wish to understand what steps your facility has taken to bring yourselves into compliance with Jarden Corporate’s Policy D-12, dated January 9, 2013 (updated on Nov, 14, 2013). As well as what guidance and/or support may be required to support adherence to the export policy. It is important to note, Jarden is a U.S. Company and U.S. Export Controls apply for any export from a Jarden company anywhere in the world.

38. Are you familiar with Jarden Corporate’s Policy D-12 regarding exports?

a.Yes, we have read it and are familiar with this policy

b.Yes, we have heard of it, but it has not yet been reviewed

c.No, we did not know it existed

d. Other

Remarks: (Must complete if “Other” was selected)

39. Does your facility export?

a.Yes

b. No

c. No, we do not export at all.

40. Are the same individuals/department, responsible for imports, also responsible for exports?

a. Yes, same individual and/or team of people are responsible for export as well as imports

b. No, different individual and/or team of people are responsible for exports, but they are in the same department. Explain in “Remarks”

c. No, different individual and/or team of people are responsible for export and they are in a completely different department. Explain in “Remarks”

d. Other

40a. Where does the Export function reside?

Finance

Operations

Sales

Supply Chain

Remarks: (Must complete if “Other” was selected)

41. Who does the individual/team of people responsible for exports report to within your organization (for example, Director of Supply Chain, VP of Accounting, etc.

42. Does the individual/team responsible for export focus strictly on Export or do they have other responsibilities? List below the other responsibilities. Select all that apply.

Why are we asking? We are interested to understand if the individual(s) responsible for export have other responsibilities or if they are solely dedicated to export.

Remarks: (Must complete if “Other” was selected)

43. Does your facility have documented export processes?

Definition: Operational export processes include filing export declarations with government, record keeping, creation and management of: export documentation, certificates of origin and free trade agreement certificates.

a. Yes, we have documented procedures that describe our operational export processes.

b. No, we do not have documented procedures that describe our operational export processes.

c. Other

Remarks: (Must complete if “Other” was selected)

44. Does your facility have documented export controls?

Definition: Export control processes are the foundation of export compliance and include export classification, denied / sanctioned party screening, embargoed country screening and antiboycott compliance.

a. Yes, we have documented procedures that describe our export control processes.

b. No, we do not have documented procedures that describe our export control processes.

c. Other

Remarks: (Must complete if “Other” was selected)

45. Have the individuals responsible for the Export function received training? Hold certificates or licenses? Select all that apply.

a. Yes, received training. Explain in “Remarks”

b. Yes, received license or accreditation. Explain in “Remarks”

c. No training

d. No, learned through experience

e. Other

Remarks: (Must complete if “Other” was selected)

46. How long does your facility retain Export records?

a. 0 through 4 years

b. 5 years

c. 6+ years

d. We do not maintain records, our freight forwarder (shipping company) maintains on our behalf

e. Other

Remarks: (Must complete if “Other” was selected)

47. How are export documents generated? Select all that apply. If a combination of methods used to generate export documents, in “Remarks” please describe.

a. From ERP

b. From Warehouse Management System

c. From 3rd Party Export Software.

d. Manually generated in MS Excel or Word

e. Other

Remarks: (Must complete if “Other” was selected)

48. Is the commercial invoice generated for export and customs purposes, the same invoice generated for invoicing (account receivable) purposes? If “No” does your facility validate that the values on the export invoice equal the value on the accounts receivable invoice?

a. Yes

b. No, but we have a validation process to ensure export invoice equals accounts receivable invoice. Briefly describe process in “Remarks”

c. No, and we do not have a process in place to validate that export invoice equals accounts receivable invoice.

d. No, because we only export samples and prototypes, so there is not an Account Receivable invoice.

e. Other

Remarks: (Must complete if “Other” was selected)

49. Does your facility perform Denied Party Screening? Also known as “Restricted Party” and “Sanctioned Party” screening.

Denied Party Screening: Denied Party Screening is a compliance control that prevents doing business with prohibited/restricted entities, including governments or individuals. Governments of various countries, as well as international organizations, e.g., United Nations, maintain a variety of lists of these types of entities. Screening means checking to see if an entity of interest to the organization appears on one or more of these lists. See Jarden Corporate Export Policy (D12) for details on requirements.

a. Yes – If “Yes” explain briefly in “Remarks”

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

50. Does your facility have controls to prevent shipping to an embargoed country? The U.S. has an embargo list that prevents shipments from any U.S. company to be sent to Northern Korea, Cuba, Syria, Iran, etc. Other countries have their own restrictions. See Jarden Corporate Export Policy (D12) for details on requirements.

a. Yes – If “Yes” explain briefly in “Remarks”

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

51. Does your facility have other restrictions on countries it can export to? For instance, your country does not have trade relations with a country, so goods must be transshipped via another country.

a.Yes – If “Yes” explain briefly in “Remarks”

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

52. Does your facility perform Antiboycott screening?

Anti Boycott Screening: Antiboycott Laws prohibit U.S. companies from furthering or supporting the boycott of Israel sponsored by the Arab League, and certain other countries, including complying with certain requests for information designed to verify compliance with the boycott. See Jarden Corporate Export Policy (D12) for details on requirements.

a. Yes – If “Yes” explain briefly in “Remarks”

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

53. Does your facility have Deemed Export controls? [To be completed by U.S. based companies/facilities only]

Deemed Export: Release of technology or source code subject to the Export Administration Regulation (EAR) to a foreign national in the United States is “deemed” to be an export to the home country of the foreign national under the EAR. .

a. Yes – If “Yes” explain briefly in “Remarks”

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

54. Does your facility have routed export transactions?

Definition: A routed shipment is when your customer nominates the freight forwarder that will submit the export declaration to your government, and will coordinate the transportation from your country to the country of destination. Why we are asking? We are interested to know if the nominated freight forwarder and your customer are responsible for the accuracy of declaration to your government, or if your company is responsible for declaration compliance and recordkeeping, even though the freight forwarder is not working for your company. Routed shipments normally happen when terms of sale are Ex-works or FCA.

a. Yes – We have routed shipments, but our country does not hold us responsible for export declaration compliance and recordkeeping. Please explain briefly in “Remarks”

b. Yes – We have routed shipments, and our country does hold us responsible for export declaration compliance and recordkeeping. We do have processes in place to ensure accuracy of those declarations and we maintain export records. Please explain briefly in “Remarks”

c. Yes – We have routed shipments, and our country does hold us responsible for export declaration compliance and recordkeeping. We do not have processes in place to ensure accuracy of those declarations and we maintain export records. Please explain briefly in “Remarks”

d. No - We do not have routed shipments

e. Other

Remarks: (Must complete if “Other” was selected)

In this section the intent is to understand the process at your facility for reviewing a new product and determining the Harmonized Schedule (HS) for export. Hence forth we will refer to this process as “classification”. In this section we will also ask questions inquiring what other export process and control information is ascertained during the classification process, i.e., free trade eligibility, license determination, etc

Export Classification Process (If Import and Export Classification Process Separate)

55. Does your facility review a product to determine if export controls apply at the time the product is being classified? Select all that apply.

a. We assign the Export Harmonized Schedule, i.e., Schedule B Nbr

b. We assign the Export Control Numbers, i.e., Export Control Classification Number (ECCN) in US or EU General Export Authorisations in European Union.

c. We determine if product requires an Export License

d. We determine the admissibility of the product in the country of ultimate destination

e. Other

Remarks: (Must complete if “Other” was selected)

56. Where does the central repository for tariff classification information and other pertinent customs data reside?(Select all that apply)

a. Spreadsheet

b. Database (in-house developed)

c. 3rd Party Customs and Trade Software Package (Global Trade Management – GTM)

d. ERP system

e. Other

Remarks: (Must complete if “Other” was selected)

57. At what point in the process does your facility classify its products for export?

a. When the part is set up

b. Prior to purchase orders being issued by the customer

c. Prior to product shipping to the customer

d. We don’t classify our products for export

e. Other

Remarks: (Must complete if “Other” was selected)

58. Describe the approach and responsibility for export classification at your facility. Select all that apply.

a. We internally (your facility) classify our products

b. The customs representative classifies our product

c. We internally (your facility) in conjunction with our customs representative classify our product

d. Our US or EU headquarters classifies our product

e. We internally (your facility) in conjunction with our US or EU headquarters classify our product

f. We use a 3rd party to classify our products. If this is the case, explain in other, who this party is.

g. The vendor/manufacturer informs us of the classification.

h. Other

Remarks: (Must complete if “Other” was selected)

59. Are all new product classifications reviewed and approved by a second party/individual prior to them being utilized? If so, explain in “Remarks” who that party/individual is

a. Yes

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

60. If your facility classifies product internally, explain the individual or team’s training to classify.

a. Have received formalized training. If so, describe in “Remarks” that training.

b. Have learned through experience. If so, describe in “Remarks” that experience.

c. Have not received training, but it is just common sense, we look through the book for the closest HS code.

d. Other

Remarks: (Must complete if “Other” was selected)

61. Describe the materials utilized to classify the product. Select all that apply

a. Product Specifications

b. Product Drawings / Pictures

c. Bill of Materials (BOM)

d. Marketing Materials

e. Product Samples

f. Base strictly on the product description in our internal systems

g. Base strictly on the product description on the commercial invoice

h. Other

Remarks: (Must complete if “Other” was selected)

62. Is export classification methodology and support (for example, product specifications, advisory opinions, Customs rulings, etc.) retained in a centralized database or management system?

a. Yes

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

63. Has the Company obtained Binding Tariff Informations (“BTI’s” or customs rulings) from Customs authorities on any of the Company’s products?

a. Yes

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

64. Does your facility review and validate a product’s eligibility for duty preference programs or Free Trade Agreements in the customer’s destination country when classifying a product for export? If “Yes” briefly describe in “Remarks” that process.

Yes

Other

Remarks: (Must complete if “Other” was selected)

65. Does your facility review a product to determine if export controls apply at the time the product is being classified? Select all that apply

a. We assign the Export Harmonized Schedule, i.e., Schedule B Nbr

b. We assign the Export Control Classification Number (ECCN)

c. We determine if product requires an Export License

d. We determine the admissibility of the product in the country of ultimate destination

e. Other

Remarks: (Must complete if “Other” was selected)

Valuation

Jarden Corporate is undertaking a global valuation study focused on all Jarden intercompany transactions whereby information will be gathered on all tax related transactions and other payments (royalty, management, service) to determine whether those transactions have an impact on the customs value declared globally. Further, the study will seek to improve processes and communication between key stakeholders within the business unit to ensure that the customs value is properly captured. The below information will provide key trade intelligence for the study to help identify any potential customs valuation risks present within your Company.

66. Does your Company import merchandise from Related Parties?

Definition: Any transaction (import) from a Jarden company.

a. Yes

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

67. If so, what method of valuation do you use for Related Party imports (check all that apply)?

a. Transaction Value

b. Transaction Value for the Same or Similar Goods

c. Deductive Value

d. Computed Value

e. Fallback method (Reasonable method)

f. Other

Remarks: (Must complete if “Other” was selected)

68. Are any prices provisional (subject to later alteration; temporary or conditional) at the time of declaration to customs authorities?

a. Yes

b. No

Other: ( Must provide remarks if this option is selected)

69. Is the final price paid reported to customs at a later date?

a. Yes

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

70. Are any quantities provisional at the time of declaration to customs authorities?

a. Yes

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

71. Is the final quantity reported to customs at a later date?

a. Yes

b. No

c. Other

72. Does the Company have any of the following included in the intercompany transactional structure? Select all that apply.

a. A buying agent (works on your behalf)

b. A selling agent (works on the related supplier’s behalf)

c. A middleman trading company overseas

d. A middleman trading company in your country

e. Another company that acts as importer and/or exporter of record

f. None

g. Other

Remarks: (Must complete if “Other” was selected)

73. Does your company make any additional payments that relate to imports but are made separately from the invoice payment for the finished goods? Select all that apply.

a. Royalties or Licensing Fees

b. Assists (materials, tools/dies/molds, merchandise consumed in production, or engineering/design/development)

c. Management Fees

d. Selling Commissions

e. Packing Costs

f. Proceeds of subsequent resale, disposal or use

g. None

h. Other

Remarks: (Must complete if “Other” was selected)

74. Does your facility have processes in place to report these payments to the local customs authorities?

a. Yes

b. No

c. Other

Remarks: (Must complete if “Other” was selected)

Transactional Questions for Imports and Classification

75. Annual Import Declarations Submitted to Customs.

Number of Entries / Declarations	Currency	Annual Import Value	Annual Duties	Annual VAT	Annual other Taxes	Time Period	(Fiscal Yr)

76. Total volume of imports for your facility annually. Complete all that are applicable.

	Response	Time Period (Fiscal Yr)
Shipments (Total whether air, ocean, truck).

FEUs (Ocean - Full 40’ equivalent)

CBMs - Ocean(Ocean LCL - Less than Container Load)

Full Trailer Loads (Imports by truck – Over road border crossing)

CBMs - Truck(Truck LTL - Less than Truck Load)

77. Top 5 Import Harmonized Schedule Numbers.

	Harmonized Schedule	Import Value	Duties Paid	Currency Type	Time Period (Fiscal Yr)
1.

2.

3.

4.

5.

78. Total unique Import Harmonized Schedule Numbers utilized annually.

79. Approximately how many product numbers does your facility classify for import per year (indicate if at the model, part number, sku level or other)?

80. Top 5 Import Countries of Origin (Where Goods Manufactured). Time Period

	Country of Origin	Import Value	Duties Paid	Currency type	Time Period (Fiscal Yr)
1.

2.

3.

4.

5.

81. Top 5 Import Traffic Lanes. All Modes Except Air

	Approximate Number of full 40’ Containers (FEU) or Trailer loads (FTL) (CMBs if not full unit)	Overseas Port of Export (Port the goods shipped from)	Port of Unlading(Port the goods unloaded from vessel)	Final Destination (City, Country where goods delivered, i.e, DC or Factory)	Location Customs Clearance (City & Country or port where Customs cleared)	Time Period (Fiscal Yr)
1.

2.

3.

4.

5.

82. Related Party Transactions for Imports – Indicate the related parties, i.e., sister companies, related factories, etc, in which you import products from. List the top 5 only. Time Period

	Ranking	Related Party Name	Related Party City, Country	Annual Value of Imported Goods	Currency type	Time Period(Fiscal Yr)
1.

2.

3.

4.

5.

Transactional Questions for Exports

83. Annual Export Declarations/Entries Submitted to Customs and/or Export Authorities. Time Period

	Number of Entries / Declarations	Currency	Annual Export Value	Annual VAT (if Applicable)	Annual other Taxes (if Applicable)	Currency type	Time Period (Fiscal Yr)
.

84. Total volume of exports from your facility annually. Complete all that are applicable. Time Period

	Response	Time Period (Fiscal Yr)
Shipments (Total whether air, ocean, truck)

FEUs (Ocean - Full 40’ equivalent)

CBMs - Ocean (Ocean LCL - Less than Container Load)

Full Trailer Loads (Export by truck – Over road border crossing)

CBMs - Truck (Truck LTL - Less than Truck Load)

85. Top 5 Export Harmonized Schedule Numbers. Time Period

	Harmonized Schedule	Export Value	Currency type	Time Period (Fiscal Yr)
1

2

3

4

5

86. Total unique Export Harmonized Schedule Numbers utilized annually

87. Approximately how many product numbers does your facility classify per year for Export (indicate if at the model, part number, sku level or other)?

88. Export customers and ship to locations, annually. Time Period

Assistance from your IT department may be required to answer this question

	Response	Time Period (Fiscal Yr)
Unique “sold to” customers

Unique “ship to” destinations

89. Domestic customers and ship to locations, annually. Time Period

Assistance from your IT department may be required to answer this question

	Response	Time Period (Fiscal Yr)
Unique “sold to” customers

Unique “ship to” destinations

90. Top 5 Countries Export to. Time Period

	Country of Export	Export Value	Currency type	Time Period (Fiscal Yr)
1

2

3

4

5

91. Top 5 Export Traffic Lanes

	Approximate Number of full 40’ Containers (FEU) or Trailer loads (FTL) (CMBs if not full unit)	Ex-Works Location (City & Country where goods shipped from, i.e., DC or Factory)	Port of Export (Port the goods shipped from)	Location of Export Customs Clearance (City & Country or port where Customs cleared – If applicable)	Country of Destination	INCOTERMS & Location (I.E., Ex-Works New York; FOB Hamburg, etc)	Time Period (Fiscal Yr)
1

2

3

4

5

92. Related Party Transactions you Facility Exports to – Indicate the related parties, i.e., sister companies, your facility exports to. List the top 5 only.

	Related Party Name	Related Party City, Country	Annual Value of Export Goods	Currency type	Time Period (Fiscal Yr)
1

2

3

4

5

93. Indicate the customs representatives / Freight Forwarders your facility utilizes for export.

	Customs Representative / Freight Forwarders	Main Contact	Phone Number	% of Export Business Managed (by Value)	Nominated by “Jarden Company” or “Customer
.

.

.

.

94. Additional information and/or comments

Individuals who Assisted in Completion of the Questionnaire (Optional)

	Name	Title	Email	Remarks
.

.

.