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SAP GTS - US Reexport Controls

Introduction: The U.S Department of Commerce regulates exports and re-exports of "dual-use" items through EAR (Export Administrative Regulations). If any controlled product is of U.S origin or in anyway connected with U.S then even if it's shipped anywhere from outside the U.S to any other countries, it should be compliant with EAR and require a license from the U.S BIS (Bureau of Industry and Security). When a foreign-based company imports products or components from the U.S and uses them in its production, and then exports the produced materials to another country, the process is known as U.S. Re-export and is subject to U.S. regulations.  Firstly, we need to determine if any foreign-produced materials that contains the U.S origin components are subject to EAR or exempted based on the de-minimis exception. Here the ultimate destination countries are classified as "Non-Critical / Friendly Countries" and...

SAP GTS Modules

SAP GTS Modules


Compliance Management:

Sanctioned Party Screening (SPL):

  • This sub-module is mainly used for screening the business partners used in the import/export transaction.
  • Business partners are screened to make sure the company is not doing business with any bad/restricted persons/terrorists/entities.
  • We can use different search comparison procedures like SAP GTS / SAP TREX / SAP HANA search algorithms in SAP GTS 11.0. 
  • However we can use only SAP HANA search procedure/algorithm in the latest SAP GTS, edition for S4 HANA.
  • In outbound transactions (export) we can screen the partner functions like sold-to-party, ship-to-party, bill-to-party, payer, End user/Ultimate consignee, contact persons, Freight forwarders/Carriers and any client-specific partner functions on the sales order / Outbound delivery / Customs export declaration.
  • In Inbound transactions (import) we can screen the partner functions like vendor, Goods supplier, Freight forwarders/Carriers and any client-specific partner functions on the Purchase order / Inbound delivery / Customs import declaration.
  • E-mail functionality can be enabled to send mail to particular person for any blocked business partners / documents in SAP GTS-SPL screening.
  • SPL content can be manually maintained for the SPL list types or it can be purchased from a data provider like Descartes, Dow Jones etc.
  • This screening helps to avoid any trade penalties due to any compliance violations.

 Embargo:

  • This sub-module is mainly used for screening the business partner countries used in the import/export transaction.
  • Business partners are screened to make sure the company is not doing business with any embargo nations as listed by the United Nations.
  • We can maintain full embargo / partial embargo situations in SAP GTS.
  • For full embargo, currently we have Iran, Cuba, Syria, Sudan, North Korea in the Embargo list. (Full Embargo - No countries are allowed to have business with these countries)
  • There could be any client specific / partial embargo situations, where few other countries like China, Venezuela, Russia, Belarus can be added to the Embargo list for any specific countries. (For ex: Partial embargo between US to CN, US to RU, etc..)
  • In outbound transactions (export) we can screen the partner functions like sold-to-party, ship-to-party, bill-to-party, payer, End user/Ultimate consignee, contact persons, Freight forwarders/Carriers and any client-specific partner functions on the sales order / Outbound delivery / Customs export declaration.
  • In Inbound transactions (import) we can screen the partner functions like vendor, Goods supplier, Freight forwarders/Carriers and any client-specific partner functions on the Purchase order / Inbound delivery / Customs import declaration.
  • E-mail functionality can be enabled to send mail to particular person for any blocked business partners / documents in SAP GTS-Embargo screening.
  • This screening helps to avoid any trade penalties due to any compliance violations.

 Legal Control (Licensing):

  • This sub-module is mainly used for checking the license requirement for any transactions (inbound/outbound).
  • License check is based on the classification number (Control Code), Country of destination. Licenses can be maintained in SAP GTS as license master.
  • For US AES exports, if the product is not listed in Commerce Control List (CCL) based on the ECCN number then we can apply C33(NLR - No license Required) license type in the legal control. We can default copy this license from legal control to the export declaration. If license is required, then appropriate department license to be maintained in SAP GTS. (For ex: C30 - IVL (Individual Validated License) license can be maintained for value/quantity-based license)
  • License Determination Rules can be maintained manually or purchased from a data provider to load the rules to pick the right license type for any transaction based on the ECCN, country of departure/destination, Control grouping number (Grouping the ECCN’s to reduce this LDR entries)
  • In outbound transactions (export) we can screen the partner functions like sold-to-party, ship-to-party, End user/Ultimate consignee, and any client-specific partner functions on the sales order / Outbound delivery / Customs export declaration. Transit countries can be checked based on the route in the export declaration.
  • In Inbound transactions (import) we can screen the partner functions like vendor, Goods supplier,  and any client-specific partner functions on the Purchase order / Inbound delivery / Customs import declaration. 
  • E-mail functionality can be enabled to send mail to particular person for any blocked business partners / documents in SAP GTS-License Check.
  • This license check helps to avoid any trade penalties due to any compliance violations.
  • Outcome of the compliance violations can be hefty fines, tarnished reputation, imprisonment, losing business license and credibility.
  • Some of the export violations penalties are – In 2017, $1.19B Penalty imposed to a Chinese company for Export Violations to Iran & North Korea. In 2017, 40 months imprisonment to a Singapore man for his plot involving exports to Iran of US Components.

 Customs Management:

 Product Classification:

  • This sub-module is mainly used for classifying the products with HS (Harmonized System) Codes.
  • For Imports, we use the HTS (Harmonized Tariff Number) for classifying the products. Length/structure of the HTS number can vary from country to country. Ex: For US, HTS number length is 10 digits. For DE, HTS number length is 11 digits. But most of the numbering scheme will share the same chapters, sub-chapters.
  • For Exports, we use the Commodity Codes/Schedule B/Combined Nomenclature (CN) codes for classifying the products. Length/structure of the Commodity Codes can vary from country to country. Ex: For US, Schedule B code length is 10 digits. For DE, CN code length is 8 digits. But most of the numbering scheme will share the same chapters, sub-chapters.
  • Product classification is an important process for customs management.
  • Product classification number is a mandatory field to be shared with the customs to identify the product involved in the transaction.
  • In Imports, the HTS number will be used to calculate the duty cost of the product.
  • Product classification content can be maintained manually / purchased from a data provider (for ex: Descartes) and loaded in the SAP GTS system.
  • Since SAP GTS is a trade system, it’s a good practice to maintain the product classification in SAP GTS and retransfer to the feeder system (SAP ECC/ S4 HANA) through standard SAP retransfer program.

 Customs Import/Export/Transit Declaration:

  • This sub-module is mainly used for creating the customs declarations in SAP GTS for declaring with the customs.
  • Export Customs declaration can be created in SAP GTS with reference to an invoice/pro-forma invoice in SAP feeder system. SAP GTS can also be integrated with SAP TM/EWM to have the integrated supply chain management.
  • Import Customs declaration can be created in SAP GTS with reference to a Purchase Order, Inbound Delivery (Prior to GR) / with reference to GR.
  • Intercompany export invoices can also be used to create the import declaration based on the customs invoice document in SAP GTS.
  • Transit declarations/procedures are used to transport the duty un-paid goods within a customs territory. It can be created with reference to an inbound delivery/shipment notification by providing the previous document type (T1/T2) and MRN as preliminary document number. Non-community goods are transported in the T1 transit procedure. Community goods are transported in T2 transit procedure.
  • Customs forms can be printed out from the customs management declarations which can be presented to the customs during the shipment. For ex: US SLI, Packing list can be printed from the US export declaration, US Immediate Entry (CBP Form – CF 3461) and the US Entry Summary (CBP Form – CF 7501) can be printed from the US Import declaration. For DE export declaration, DE AES Customs system send the EAD form to SAP GTS system via webservice.
  • Special customs procedures with inventory linked process like Bonded Warehouse, US FTZ/Inward/Outward processing can be performed in Customs management module.

 Risk Management:

 Preference Management:

  • This sub-module is mainly used for Requesting Vendor Solicitation, Preference determination for the fixed/document BOM’s and providing Certificate of Origin form to the Customer.
  • Preference management is mainly used to avail the Free Trade Agreement (FTA) benefits by reducing the duty cost for any transactions withing the FTA countries.
  • Rules of Origin can be maintained manually/uploaded through the content from the data provider, which is used for the preference calculation in SAP GTS.
  • Master data (like materials, BOM’s, Procurement types, Product prices) from SAP feeder system to be transferred to GTS.
  • Preference agreements that are active in SAP GTS to be in sync with SAP feeder system.
  • Products should be classification with the HTS number to have the preference calculation performed in SAP GTS.

 Letter of Credit (LOC):

  • This sub-module is mainly used for mitigating the financial risks involved in both import/export transactions in the global trade.
  • Letter of credit received from the banks can be maintained in SAP GTS as master data.
  • There are three types of LOC that can be maintained – Revocable, Irrevocable- unconfirmed, Irrevocable-Confirmed
  • Irrevocable LOC is the most common one which cannot be amended without the permission of all the involved parties. Whereas revocable LOC which is uncommon can be amended by the issuing bank for any reason without any permission from all the parties.

 Restitution:

  • This sub-module is mainly used for supporting restitution process for the exporters with export subsidies mainly for the agricultural products.
  • Restitution would benefit the exporters/traders to cover the commodity price difference between the higher internal price against the lower export price.
  • Common Agriculture Product numbers and license can be maintained in SAP GTS and can be used in the export declaration.
  • Restitution rates can be maintained in SAP GTS.

 Electronic Compliance Reporting (ECR):

 Intrastat:

  • This sub-module is mainly used for reporting intra-EU community transactions to the relevant customs authorities.
  • Intra-European Community Trade Statistics (Intrastat) is a system for collecting the statistics on imports/exports among member states of the European Union (EU).
  • Intrastat declaration will cover the flow of incoming goods (arrivals)  / outgoing goods (dispatches)
  • Extrastat which covers the transaction statistics with any non-EU countries might no longer be existing due to customs get the required details from the export declarations.

For any queries/suggestions/corrections please drop a message. Happy Learning...               

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