For Immediate Release

Ways to Prepare for New FDA Import Rules
PBB Global Logistics offers tips for shipping food to the U.S.

Fort Erie, Ontario –November 24, 2003 –With new Food and Drug Administration (FDA) import regulations coming into effect on December 12, PBB Global Logistics is offering a number of strategies and tips to help Canadian food exporters avoid hiccups with their cross-border supply chain.

The new rules fulfill the FDA’s mandate under recent U.S. homeland security legislation to strengthen the safety of the U.S. food supply. Mandatory registration of domestic and foreign food facilities and stricter recordkeeping standards are two main provisions of the new FDA rules. However, the third provision, requiring submission of food shipment data prior to entering the U.S., may be the most exigent rule facing the industry. The rules also require Canadian food exporters have a U.S. agent.
“ The impact of the prior notice requirement will be substantial,”says Jack Rafferty, Managing Director, Trade & Regulatory Services, PBB Global Logistics. “Depending on the readiness of all parties involved –the FDA, U.S. Customs, the food industry and supply chain partners –we could face serious bottlenecks at the border starting December 12.”

Rafferty pointed out a number of complexities with the submission process. For example, shippers will be required to provide notice and receive confirmation from the FDA, a minimum two hours before arrival at Customs by truck, four hours by air and eight hours by vessel. Approximately 30 data elements are involved with each notice, and each product variation within a shipment must be reported in a separate notice. So, for example, a shipment with three different bottle sizes requires three prior notices. “Collecting and transmitting shipment data within the required timeframe will be a challenge for many shippers,”says Rafferty. “And the FDA’s ability to receive and process the data in a timely manner remains to be seen.”

To help businesses prepare for these challenges come December 12, Rafferty offers a number of strategies:

1. Increase your safety margin in the U.S., particularly for businesses with Just-In-Time supply chains or high turnover ratios. This strategy, however, could prove difficult for certain perishable food importers.
   
2. Ensure your carriers are prepared. Ideally, truck carriers should have a SCAC code and participate in the Pre-Arrival Processing System (PAPS) where available.
   
3. Confirm in advance all Harmonized Tariff System classifications (H.S. codes) and FDA product codes, which are on file with your Customs broker.
   
4. Detail your shipment invoices carefully. Information such as the FDA facility registration number, food product descriptions, sizes, quantities, packaging, unit values and total values must be accurate and clearly listed.
   
5. Avoid “complicated”shipments, such as food articles that invoke multiple import regulations. For example, a food basket with cheese and sausage may be subject to dairy quotas and USDA meat regulations, in addition to FDA prior notice.
   
6. If possible, try to ship full loads of a single food product of the same size and with the same packaging. The fewer prior notices involved with each shipment, the more efficient clearance should be at the border.
   
7. Be an early bird! The FDA will allow prior notice up to 5 days in advance of shipment. If all your data elements are known ahead of time, submit early to avoid last-minute complications.
   

As a service to the trading community, the company recently launched a new section of its Web site dedicated exclusively to the new FDA rules at www.pbb.com/fda. The site offers a comprehensive resource center for food exporters, including fact sheets, questions and answers, a white paper, forms and helpful links to the FDA’s own registration Web site.

PBB Global Logistics is a leading provider of third party international logistics services, facilitating the movement of goods across North America and around the world. Founded in 1946, PBB has expanded its core Customs brokerage and freight operations and now provides supply chain solutions, from the point of origin of goods to the point of consumption, as well as corporate travel management and professional trade services. With approximately 900 employees in over 70 strategic locations throughout North America and an established global network of logistics service providers, PBB has the technology, expertise, and infrastructure to meet every supply chain need. PBB Global Logistics is a wholly owned subsidiary of PBB Global Logistics Income Fund with units trading on the Toronto Stock Exchange under the symbol PBB.UN.

For more information contact:
1-800-924-4466 ext. 3634
info@pbb.com
www.pbb.com