Problems with Cargo Bookings into PR continue; so does the lack of adequate Inventory in our Island

Members of the Trade, Importers/Exporters, Friends:

This article confirms what members of our Industry have been expressing to our Committee; “Not only we have to continue facing the lack of space for cargo coming Southbound from the US to PR, but we also have a Shortage od Drivers/Trucks in the Mainland”.

If we add this to having to pay CRIM Tax on these Inventories; we do have “The Perfect Storm” as a good Friend of mine use to say. Under these circumstances, having the adequate supply of food, construction material, etc., is very difficult. But changing the Tax into another National Patente for three times the amount actually collected, is not the answer either.

Not only do we agree that in an emergency, requesting an exception from “Ley de Cabotaje” is a most; but also on the fact that such exception should last a few months, not only 10 days as it happened after maria.

We continue to push the fact that “Bulk Cargo” should be exempted from “Leyes de Cabotaje”, this would lower Manufacturing Costs as well as Electricity Costs in our Island. We have approached Resident Commissioner Jennifer Gonzalez on this issue, as we have approached previous Resident Commissioners in the past.

PR should also be exempt from having to file the Electronic Export Information (EEI) to US Customs on shipments over $2,500, since PR is part of the Customs Territory of the USA https://www.usitc.gov/tata/hts/archive/8910/891gn.pdf. This is another matter that increases the cost of everything we buy, since we are treated as International in terms of Rates by the Carriers. The definition of who must file, as provided by CBP (Customs & Border Protection), is as follows:

When do I need to prepare the Electronic Export Information (EEI) formerly Shipper's Export Declaration (SED) to be filed with CBP?

The Electronic Export Information (EEI) needs to be filed when the value of the commodity classified under each individual Schedule B number is over $2,500 or if a validated export license is required to export the commodity. The exporter is responsible for preparing the EEI and the carrier files it with U.S. Customs and Border Protection (CBP) through the AES or AES Direct.

This has also been brought to the attention of Governors and resident Commissioners for Years, and the concept has been endorsed by the Fiscal Oversight Board (PROMESA), and the incumbent Resident Commissioner Jennifer Gonzalez.

There are many problems affecting the Supply Chain and that is why we see these problems which will complicate further if another Hurricane hits our Island. It will be complicated also by the Path of those who miraculous will not touch us, but we are in their path, and there is nothing we can do about that.

There things we cannot change, but there are others we can and we must. We as Citizens must request from our Political Representatives to make the changes necessary for the EEI not to be filed, for eliminating the Inventory Tax (CRIM), and for requesting from Congress that they allow Bulk Cargo to be exempted from “Leyes de Cabotaje” as well as Obtaining “Libertades Aereas” (HR 3472 - Puerto Rico (PR) Air Cargo Industry Empowerment ACT) for our Airports.

“Let’s make a difference in our future so we do not suffer from the same mistakes of our past”.

Edmundo Rodriguez, CHB – President “Comité de Logística y Transportación” PRMA

also President of NRI, Inc. - US Customs Brokers & Foreign Freight Forwarders

www.nreyes.com