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June 17, 2011


PCCS is seeking a new Management Analyst. Click here for details.

November 16, 2008


Ms. Dinah Shih, Bona fide

PCCS would like to congratulate are own Ms. Dinah Shih, on passing her exam, (on her first try) to become a Certified Customs Specialist. Good show!

November 14, 2008



TYPE OF ALERT: Detention Without Physical Examination (Countrywide)

(Note: This import alert represents the Agency's current guidance to FDA field personnel regarding the manufacturer(s) and/or products(s) at issue. It does not create or confer any rights for or on any person, and does not operate to bind FDA or the public).

PRODUCTS: All milk products
All milk derived ingredients
Finished food products containing milk

CODES: 03[][][][] Bakery Products/Doughs/Mixes/Icings

05Y[][][] Cereal Preparations
05A[][][] Breakfast Food Ready to Eat
05B[][][] Breakfast Food Quick Cook

07[][][][] Snack Foods

09[][][][] Milk/Butter/Dried Milk Products

12[][][][] Cheese/Cheese Products

13[][][][] Ice Cream Products

14[][][][] Filled Milk/imitation Milk Products

29A[][]70 Soft Drink, Milk Based (Chocolate Flavored),
29A[][]99 Noncarbonated Soft Drink, N.E.C.
29Y[][]99 Soft Drink/Waters N.E.C.
29B[][]70 Soft Drink, Milk Based (Chocolate Flavored, Etc.)
29B[][]99 Carbonated Soft Drink, N.E.C.

30F[][][] Beverage Base N/Fruit (Cola Rootbeer Etc)
30G[][][] Beverage Base Non-Fruit Liquid

33G[][][] Soft Candy w/ Nut, seeds, w/out Coconut
33H[][][] Soft Candy w/ Coconut
33J[][][] Soft Candy w/ Fruit
33K[][][] Soft Candy w/ Nuts & Fruits
33L[][][] Soft Candy, w/out Nut/Fruit
33S[][][] Candy Specialties
33Y[][][] Candy w/out Chocolate, N.E.C.

34[][][][] Chocolate/Cocoa Products

35C[][][] Custard Pudding mix
35D[][][] Pudding Mix (Not Custard)

40[][][][] Baby Food Products

67A[][]28 Iodinated Casein (Cat. I, Type A med. Article)
67C[][]28 Iodinated Casein (Combo Cat. I& II, type A, med)

69A[][]28 Iodinated Casein (Cat. I med. feed)
69C[][]28 Iodinated Casein (Combo Cat. I & II, med. feed)

71C[][][] Dairy Byproducts for Animals
71E[][][] Animal Waste Feed Products
71Y[][][] Byproducts for Animals, N.E.C.

72A[][][] Pet Cat Foods
72B[][][] Pet Dog Foods
72D[][][] Pet Fish Foods
72E[][][] Other Pet Foods, N.E.C.
72L[][][] Laboratory Animal Feeds
72Y[][][] Pet and Laboratory Animal Foods, N.E.C.

PROBLEM: Unsafe Food Additive
Poisonous or Deleterious Substance
Unfit For Food




CHARGES: “The article is subject to refusal of admission pursuant to Section 801(a)(3) in that it appears to bear or contain a food additive, namely melamine and/or a melamine analog, that is unsafe within the meaning of section 409 [Adulteration, section 402(a)(2)(C)(i)]”
OASIS charge code: MELAMINE


“The article is subject to refusal of admission pursuant to section 801(a)(3) in that it appears to bear or contain a poisonous or deleterious substance which may render it injurious to health [Adulteration, section 402(a)(1)]”
OASIS charge code: POISONOUS


“The article is subject to refusal of admission pursuant to section 801(a)(3) in that it appears to be unfit for food [Adulteration, 402(a)(3)]”
OASIS charge code: UNFIT4FOOD

OFFICE: Division of Import Operations and Policy, HFC-170
Center for Food Safety and Applied Nutrition, HFS-600

ALERT: In September 2008, FDA became aware of thousands of infant illnesses in China due to the consumption of infant formula reported to contain melamine. Reports indicated over 53,000 illnesses, including almost 13,000 hospitalizations, and at least four deaths of infants. The illnesses involved the formation of kidney stones and crystals and related complications.

The milk used in the infant formula has been implicated as the source of the melamine contamination. According to sources, at a bulk fluid milk collection point, water is added to the bulk fluid milk to increase the apparent volume of product. Melamine is added to the water/milk mixture to increase the nitrogen content in order to inflate the apparent protein content found in the product. Milk is transported from the collection centers to milk processing facilities.

The problem of melamine contamination is not limited to infant formula products. Chinese government sources indicate contamination of milk components, especially dried milk powder, which are used in the manufacture of a variety of finished foods. These contaminated milk components appear to have been dispersed throughout the Chinese food supply chain.

FDA analyses have detected melamine and cyanuric acid in a number of products that contain milk or milk-derived ingredients, including candy and beverages. In addition, information received from government sources in a number of countries indicates a wide range and variety of products from a variety of manufacturers have been manufactured using melamine-contaminated milk or milk-derived ingredients, including: fluid and powdered milk, yogurt, frozen desserts, biscuits, cakes and cookies, taffy-like soft candy products, chocolates, and beverages. These products appear to contain at least one milk-derived ingredient and they are of Chinese origin. Reports of contamination have come from more than thirteen countries in Asia, Europe, and Australia, in addition to the United States. Additional products from various manufacturers continue to be found to be contaminated with melamine.

The problem of melamine contamination in Chinese food products is a recurring one. In 2007, bulk vegetable protein products imported from China were contaminated with melamine and melamine analogs, apparently from deliberate contamination.

GUIDANCE: Districts may detain without physical examination all milk products, all milk derived ingredients, and finished food products containing milk from China.

Appropriate screening criteria have been set.

For questions or issues concerning science, science policy, sample collection, analysis, preparation, or analytical methodology, contact Mr. Thomas Savage, Division of Field Science, at 301-827-1026.

In order to secure release of an individual shipment detained pursuant to this Import Alert, the importer should provide either:

1. Results of a third-party laboratory analysis, of a representative sample of the lot, which verifies the product does not contain melamine or cyanuric acid. Third-party laboratories may use any method that is found acceptable to FDA and which meets the method performance of the LC-MS/MS methods available at


2. Documentation supplied in English which shows there are no milk or milk-derived ingredients in the product, to include product formulation and product labeling (for example; process or batch records from the manufacturer, and the actual product labeling or a facsimile of the product labeling).

If a firm, shipper or importer wishes to request removal from detention without physical examination, they should forward information supporting their request to FDA at the following address:

Food and Drug Administration
Division of Import Operations and Policy (HFC-170)
5600 Fishers Lane, Room 12-36
Rockville, MD 20857

The request should include information for FDA to adequately assess whether a manufacturer has appropriate controls and processes, including:

1. Documentation showing a minimum of five (5) consecutive non-violative shipments have been released by FDA based upon results of third party laboratory analyses, using methods found acceptable to FDA of a representative sample of the lot, that verify the products do not contain melamine or cyanuric acid.


2. Documentation from a third-party, in whom FDA has sufficient confidence, which demonstrates controls are in place such that products will not be contaminated with melamine and melamine analogs. To gain sufficient confidence in a third party, FDA may determine it needs to conduct a paper or on-site review of the work of the third party.


3. Documentation that the firm is in compliance with all Chinese government requirements for exporting the products to the U.S. Documentation should include copies of any registration that may be required by the Chinese government.

All requests for removal from detention without physical examination will be referred by DIOP to CFSAN (HFS-606) or CVM (HFV-232) for evaluation.


FOI: No purging required

KEYWORDS: Human food, pet food, animal feed, melamine, milk, milk-derived ingredients

PREPARED BY: John E. Verbeten, DIOP, HFC-170, 301-594-3853
Sal Evola, CFSAN, HFS-606, 301-436-2164
Linda Wisniowski, CVM, HFV-232, 240-276-9233

INTO FIARS: November 12, 2008

October 17, 2008

New CSPC Rules

A new law passed by Congress will increase Consumer Protection safety Commissions (CPSC) oversight authority on many imported products.

CPSC has new rules that would require importers to present certifications, third party testing results and compliance declarations for certain products. These new rules will become effective towards the end of 2008 and first half of 2009.

We do not have to sound the alarm to our customers yet, but, it will be worth your time to check the information found at

Please note that these new CPSC requirements apply to a variety of merchandise ranging from toys and baby cribs to ATVs (all terrain vehicles) and metal jewelry.

Softwood Lumber Act 2008 (SLA 2008) You can find a lot of info here

An overview can be found here

The SLA 2008 is a data collection program, effective Sept. 18, 2008, that requires importers to provide on the entry summary three data elements for shipments of softwood lumber. HTS numbers potentially subject to this Act can be found here

A sample CF7501 can be found here

The three elements are:
a) Export Price (Note this is different from the entry value)
b) Export Charges
c) Importer’s declaration regarding export price and export charge

E-mail questions concerning any aspect of the SLA 2008 may be addressed

Lacey Act Amendment. There isn’t much about this at the CBP website, but you can find some info here and here.

Lacey Act Amendment- Customs has not yet developed its implementation program. It may have an effective date of as early as December 15, 2008. The main objective of this Act is to prevent illegal logging and harvesting of protected plants and trees.

The Act would require importers to make a declaration that contains the following three elements

a) Scientific name of the plant, including genus and species of the plant or wood used in manufacturing the product
b) The country of origin of the plant/tree species (the country where it was harvested)
c) A description of the value of the importation and the quantity

The scope of this Act is not very well defined and may undergo some changes. As it stands, it is very vast and includes all woods, wood products and even byproducts of wood such as rayon dress, rubber tires, books and pet shampoo (pine tar).

September 22, 2008


On August 25, 2008, CBP published an interim rule entitled “First Sale Declaration Requirement” (73 FR 49939), to implement the Farm Bill. The rule states that, effective for a one-year period beginning August 20, 2008, all importers are required to provide a declaration to CBP at the time of filing a consumption entry when, in a series of sequential sales, the transaction value of the imported merchandise is determined on the basis of the “first or earlier” sale of goods. In such case, importers are required to provide CBP with an "F" indicator next to the declared value at the line level on CBP Form 7501, or its electronic equivalent.
The following questions and answers may help clarify this requirement.
Q: What is a “series of sequential sales”?
A: A series of sequential sales, common in import transactions, consists of two or more successive contracts for sales of goods. One example is where the import transaction involves a sale between the manufacturer and a foreign intermediary and another between a foreign intermediary and a U.S. buyer.

Q: Which is the “first or earlier” sale?
A: In a series of sequential sales, as defined above, any sale occurring earlier than the last sale prior to the introduction of the merchandise into the United States would be considered a “first or earlier” sale. In the above example, the sale between the foreign intermediary and the U.S. buyer is considered the last sale prior to the introduction of the merchandise into the United States. The sale between the manufacturer and the foreign intermediary is the “first or earlier” sale.

Q: Should I place an “F” indicator when there is only one sale involved?
A: No, when the import transaction involves only one sale the reporting requirement is inapplicable. In that instance, there is only one buyer, located in the United States, and one seller, located in another country.
To comply with this requirement, we request your declaration of “First Sale”, if the shipment qualifies for such a declaration.  Please note that this declaration is required for each item on the invoice that is classifiable under a different HTS number.  Since the purchase requirements can change, this declaration has to be made for each entry.
You can make this declaration by using our suggested format of FIRST SALE DECLARATION found here.

August 28, 2008

New Rules of Origin
Have Been Proposed by CBP

From the Foreign Trade Assosiation of America, Newletter Vol 14, No 35.

The FTA signed on to a letter from AAEI to Customs and Border Protection requesting a 60-day extension to the September 23 deadline for comments on this proposed rule that would fundamentally change the way origin is determined for purposes of country of origin marking, admissibility, preferential treatment in some cases, and administration of the textile program. What can you do? First, attend our webinar on September 11th. Second, give us your comments on how the proposed rule will affect your company. You can give your comments at the seminar or by email to The FTA Advocacy Committee will prepare a letter on behalf of our members. Get involved on this important issue today! The new rules of origin can be viewed here. The request for extension can be viewed here'



August 26, 2008

Branding Redesign underway

In keeping with all things new, PCCS has commisioned a complete overhaul of the PCCS brand. As you may have noticed, the new PCCS will now include a new logo and website seen here. We hope these changes reaffirms our company's mission —To bring the highest quality of service to our valued customers.

Your suggestions are welcome, as updates will be continuous untill ultimate completion. Send your comments and suggestions to:



January 28, 2008


We are proud to announce, our company has moved. Anyone who has had visited our previous office would agree, after more than twenty years in operation, we had out-grown our previous residence.

Antony circa 2000
credit: JMC Netlink


Our new address:

2936 Columbia Street
Torrance, California 90503

We completed our relocation last January and now, we take this opportunity to invite you to come visit us. Welcome. We hope this new space serves us well, as we continue to provide the highest quality of service to our customers.









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Organizational Chart



ACH Debt Application

Terms & Conditions

Customs Power of Attorney



2936 Columbia Street
Torrance, California 90503

Phone: 310 - 670 - 1891
x x Fax: 310 - 670 - 2831
xx F ax : 310 - 410 - 2525
x x Fax : 310 - 410 - 2528
xx F ax : 310 - 755 - 7692