Monday, January 14, 2013

Spring/Summer 2014 Fashion Color Trends


While I love to be “behind the scenes” of fashion, I also love being in the forefront, and being briefed on Spring/Summer 2014 color trends today put me front and center of what’s coming next!

Thanks to a trend specialist from Stylesight, I was presented with the four (4) mega trends entitled
1)      Rational
2)      Creed
3)      Eden, and
4)      Real
 *Please keep in mind that the trend descriptions below incorporate such descriptions as provided by Stylesight and are not my attempt to claim any authority as a color trend expert – I’m just sharing the information as I know some of you readers want to know about this!

The “Rational” trend (which is actually written differently, however so as to not confuse anyone, I’ve typed it “normally” here) is about colors reflecting mineral elements and feminine minimalism that is soft - not aggressive. 

It’s about symmetrical proportion, “curvilinear” forms and creating textures, whether by using folding and pleating techniques to create light structures, or beading and embroidery.

Triangular silhouettes, repetitive geometric motifs and liquid gold and mercury colored metallics woven into fabrics are also a part of the Rational trend.

Lastly, grids and graph paper are translating to apparel within this trend.

The “Real” trend is about a look and feel of the past, altering our notion of time using filters to create an earthy palette.  Taking cues from the 1970s, head-to-toe denim (i.e., tops and pants) and even Hawaiian shirts are making a come back because it’s a return to authenticity - yes, I'm serious!

Colors in yellow, brown and rust make up this trend, as does wood and the knots and grains therein which will inspire prints in fabric.  Tortoise shell printed on material will have a comeback, with eyelet fabrics and products from recycled materials also being a trend for 2014.

The “Creed” trend looks at space and sea and thus, colors that come from the ocean and sky are what this trend is about.  These include indigo, sky, water blue, teal highlighted by bright yellow and coral colors, as well as white, whether it’s got a powdery, chalky or cracking look.  The image of a blue sky with clouds also inspires tie-dye techniques.

The use of mystical symbols, ultra sheer gauze and fabrics with beads give apparel textures.  Multiple layers of thin fabrics (again texture) as well as jersey fabrics which allow for tight body hugging designs round out this trend.

Lastly, the trend “Eden” is about embracing expression and is inspired by Central and South America.  Red, orange and fuchsia blending with acid yellow and greens along with clashing embroidery colors mark this trend. 

Graffiti art, tribal motifs, jacquards made of “ethnic references” – not sure what that means - patches, pins and colored warp to create an “eye game” are also prevalent in this trend.

In addition, woven checkers and plaids which are multi-colored, ruffles used in a grand scale and animal prints worn “to the max” make up this trend.

I wish I had images for you but since they are proprietary to Stylesight, it’s best I simply refer you to their website where you can check out their “Runway Roadmap” from Spring/Summer 2014 at www.stylesight.com.

Questions/comments?  Post below or email me at fashioncompliance@gmail.com

Wednesday, January 2, 2013

New Year, New Diet, and New Customs Rule on $2500 “Informal Entry” Limit


It’s not uncommon to find people engage in *new* things, such as a new workout routine, new diet, or maybe even a new boyfriend/girlfriend (hey, why not?) at the start of a new year.

Like people, federal agencies also start things at the new year as US Customs is doing with it’s new dollar (USD) limit for which merchandise being imported into the US may reach in order to qualify for an “informal entry.” 

For more about entry, check out this article here.

The informal entry limit is going from $2,000 to $2,500 and when an importation qualifies as an ‘‘informal entry,” it eliminates the need for a surety bond, expedites the customs clearance process, and reduces another required charge, known as the Merchandise Processing Fee (MPF) to $2 (assuming the entry is filed electronically).

New Rule Effective 07-Jan-2013

Reasons for this increase are to mitigate the effects of inflation between the United States and Canada and to harmonize the value thresholds for expedited customs clearance to $2,500 from the current levels of $2,000 for the United States and $1,600 for Canada. 

For any merchandise valued over $2,500, formal entry is required and importers must provide a surety bond (more info. on this can be found here), complete Customs form 7501 (instructions here), and pay a minimum of $25 in MPF. 
 Unless exempt under a free trade agreement, and in addition to any duty or tax owed, merchandise requiring a formal entry is subject to a 0.3464 percent ad valorem MPF, which may be no greater than $485 and no less than $25.  Formal entry also requires detailed information regarding the import transaction as well as commercial documents pertaining to the transaction.

Of course, based on his/her discretion, a port director, may always require an importer to file a formal entry.

For more information, you can read the entire final rule on the informal entry limit in the Federal Register (73 FR 72715) here.

Questions/comments?  Post below or email me at clark.deanna@gmail.com

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HAPPY NEW YEAR!

Monday, December 10, 2012

OWIT-NY Export Event This Wed. Dec. 12th 6 PM NYC


Come join me and the NY Chapter of the Organization of Women in International Trade for it's next event entitled "Export Financing Programs with the Small Business Administration (SBA) and Toni Corsini"

ALL PROCEEDS WILL GO TO THE RED CROSS SUPPORTING HURRICANE SANDY EFFORTS!
Highlights of the program agenda include:

1)      Identifying the three SBA Export financing programs and how they can help US exporters
2)      A brief overview of the Credit Insurance programs available through "ExIm Bank" for US exporters
3)      The services available to US exporters from the US Dept. of Commerce (Commercial Service)

For directions and to register, go to www.owitny.org.

Hope to see you there!

ciao ciao!
Deana


Sunday, December 2, 2012

Rising to “Official” Importer Status – Now What?


From essential oils to women’s jewelry, I’ve spoken with many small business owners whose enterprises are growing, so much so that the time has come from merely carrying back foreign articles for sale in their suitcases to actually becoming a commercial importer.

So who do you share the news with?  Well, with any good news you may want to share it with your loved ones, however you actually need to share it with US Customs and that is achieved through the submission of an "Importer ID Record," which is Customs Form 5106 (CF 5106) and may be found here.

Being an “official” first time importer, you would use this form to identify yourself to US Customs as such.  The form is also used if you are using an Importer Number for the first time, or if you have not engaged in any customs business within the past year.

The CF 5106 can also be used if there is already an importer number on file but there is a change in the name or address currently on file.

Importantly, this form has an extra box on the top of the first page to check if you also want your address updated at US Customs Fines, Penalties and Forfeitures Office.  I can’t tell you why it’s not automatically updated with that office, but I can tell you that a failure to do so via this form can leave an importer “on the hook” for the payment of a penalty for which no response had been made for mitigation or remission (i.e., “cancellation,” in everyday language) purposes.

In other words, saying that you never received a copy of the notice will not serve as a valid excuse for non-responsiveness if this form was not properly filed.  

One final note of importance is that where an importer has a continuous bond on file with US Customs, a rider must accompany the CF 5106 as well.  For more information on an importer’s bond requirements, see my article dated Sept. 16, 2009 here.

 Questions/comments?  Post below, email me at clark.deanna@gmail.com, or tweet/follow me on Twitter @fashcompliance

Tuesday, November 20, 2012

Eco-Friendly & Trade Agreement Beneficiary Gifts


With the holidays upon us, there is no shortage of vendors here in New York City offering gifts and stocking stuffers for sale. 

As I try to buy gifts made using either an eco-friendly production method or one which derives from a sustainable production environment – in terms of the workers involved – I was pleased to learn of Nakate Project’s high fashion necklaces and bracelets from Uganda that not only meet both of these standards but are also a gorgeous gift that I would be happy to give to any of my friends.
 
NOTE: As these goods come from the African continent, duty free treatment for these and thousands of other products is available under the GSP and AGOA programs.  Just another good reason to source from Africa!

Having been examining quite a bit of jewelry and accessories at my office lately, I wondered about the tariff classification of Nakate’s paper beaded necklace, an image of which can be found here. 

As this jewelry is not made of, nor contains, silver, gold or platinum, it would not be considered jewelry of a precious metal.   It likewise has no gemstones or semi-precious stones.  It further is not made of any base metal.

It therefore does not fall into these categories for classification purposes.  Rather, it falls into the classification for “Imitation Jewelry.”

Interestingly, jewelry of this kind is classified based upon a cost per quantity measurement.  (As an aside, if anyone reading this has any insight into the historical reason for this, it would be great if you could share it with the rest of us readers!)

The tariff specifically provides that if the jewelry is

… valued not over 20 cents per dozen pieces or parts, then classification will be 7117.90.5500 (HTSUS 2012) which provides for “Imitation jewelry: Other: Other: Valued not over 20 cents per dozen pieces or parts: Other.”  The rate of duty will be 7.2% ad valorem.

 OR

… valued over 20 cents per dozen pieces or parts, then classification will be 7117.90.9000 (HTSUS 2012) which provides for “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Other.”  The rate of duty will be 11% ad valorem.

 Now I don’t know about you, but these types of figures beg the question…what type of jewelry (nevermind the parts) is valued at less than 20 cents (USD) per dozen pieces?  Or in other words, what type of jewelry (not including children’s or of plastic) is only 1.67 (i.e., $0.0167) cents/piece?  Umm…and what is the quality like?

 Questions/comments?  Post below or email me at clark.deanna@gmail.com

 

Friday, November 9, 2012

How to Classify a Composite Good - Key Chain Case Study


I was admiring key chains recently that were sold separately from their corresponding designer handbags.  Noting that the ring was of metal but the decorative part was of leather, I found myself wondering if it was considered a composite good under the tariff, i.e., the Harmonized Tariff Schedule of the U.S. (HTSUS).

A “composite good” is one composed of more than one material which can be either a mixture of materials in one (1) article, an article made up of different components (as in the case of this key chain), or even goods put up in a set for retail sale (which is a term of art by the way in customs-ease and may not mean what you might think it does – so ask someone if that question arises).

Since the key chain is a composite good, we look at the HTSUS’ General Rules of Interpretation (GRI) for guidance on how to classify it.  GRI 3(b) states that when goods are prima facie (i.e., appear to be) classifiable under two (2) or more tariff headings, classification shall be determined as if they consisted of the material or component that gives them their “essential character,” insofar as this criterion is applicable.

Endnote (IX) to GRI 3(b) explains that “a composite good made up of different components shall be taken to mean not only those in which the components are attached to each other to form a practically inseparable whole, but also those with separable components, provided these components are adapted to one another, are mutually complementary, and that together they form a whole which would not normally be offered for sale in separate parts.”

Customs has consistently held that, when a key chain has both a functional and non-functional component, it is the functional component which provides the article’s essential character.  (HRL 950636) Therefore, the ring component makes up the utilitarian part of the key chain with the leather portion deemed as being merely decorative.

Provided the metal key ring was of steel, the whole key chain would therefore be classifiable under HTSUS heading 7326.

Questions/comments?  Post below or email me at clark.deanna@gmail.com

Friday, November 2, 2012

FTC Proposed Updates to the Care Labeling Rule on Apparel – Only 2 More Weeks to Submit Your Comments

Only 2 more weeks remain for you to submit your comments related to the Federal Trade Commission’s (FTCs) proposed changes to the Care Labeling Rule.

This rule requires manufacturers and importers to attach labels with care instructions for garments and certain piece goods, so consumers have reliable instructions for washing, dry cleaning, bleaching, drying and ironing their clothing.


The Care Labeling Rule, officially called the Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, has been in effect since 1971.  It requires manufacturers and importers to attach care instructions to garments.

The FTC is seeking comments on potential updates to the Rule, including changes that would:

  1. Allow manufacturers and importers, if they so choose, to include professional instructions for “wet cleaning” – an environmentally friendly alternative to dry cleaning – on labels if the garment can be professionally wet cleaned;

  1. Permit manufacturers to use updated ASTM (American Society for Testing and Materials) or ISO (International Organization for Standardization) symbols on labels in lieu of written terms providing care instructions;

  1. Clarify what constitutes a reasonable basis for care instructions; and

  1. Update and expand the definition of "dry clean" to reflect current practices and account for the advent of new solvents.

Comments can be filed electronically by clicking here as are instructions on how to file.  They must be received by November 16, 2012.

All comments received will be posted online here. (FTC File No. R511915)  The staff contact is Robert M. Frisby, Bureau of Consumer Protection (202) 326-2098 and questions about contributing and submitting comments may be directed to him.

Make your voice heard!

Questions/comments?  Post below or email me at clark.deanna@gmail.com.