WEBVTT
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Hey, welcome back to another episode of the Decoding Cross Border E-Commerce Podcast.
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I have the familiar face of Aaron here with me, but also, Aaron, today we have Angela Mackey.
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Angela is our corporate customs board broker for Zonos.
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And uh uh we're gonna talk today about partner government agencies, PGAs.
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Why don't you just use the PGA?
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Like the acronym, the acronym is because I don't I'm not a golf.
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Wait.
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Don't you love acronyms?
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Oh, you can acronym P partner Government Okay, yeah.
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And it's not confusing at all.
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Like a lot it's the only PGA possible.
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Yeah, yeah.
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When you search for it, except for golf and what other things that that that come up when you when you search for it.
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But I'm gonna start this off real quick though.
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Talk about golf.
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I went miniature golfing with my family a couple weeks ago.
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Chaos.
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That's a lot of kids.
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Absolutely.
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Oh, yeah.
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Little four-year-old running around.
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What's the number of kids?
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Eight kids.
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Eight kids, okay.
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I can so that so they you you're renting the whole mini golf course.
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Pretty much, pretty much.
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Yeah.
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But I actually learned something in the process.
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Did you know miniature golfers never get anything done?
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Do you know why?
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No.
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No.
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They have no drive.
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Okay.
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Apparently there's a podcast I didn't laugh at when you're jokes, but I laughed at that one.
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So you're welcome.
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All right.
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Angela, okay.
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Uh tell us a little bit about yourself, your background.
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Um, and uh uh yeah, I think it's helpful because we'd like to bring you on every once in a while to talk uh talk a little bit of shop around customs brokerage into the United States.
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So sure, yeah.
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Um so I've been in this industry for a little over 10 years.
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Um I am a licensed customs broker.
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I have been a licensed customs broker since 2021.
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I passed that dang exam.
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It's uh hard and long.
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But uh yeah, and I've been doing that for the past 10 years and uh I've been really enjoying it.
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Well, we're uh we're grateful to have you here.
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And uh thanks for thanks for moving to the sunny side of the state.
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Uh Angela uh in her previous life worked in northern Utah and has moved down to southern Utah.
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So, all right, we're we're excited to get into this mostly because why is this a topic right now?
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Why does this even matter?
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I mean, these these agencies have been around a long time.
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I mean, there's been a little more um, and we'll talk about the different agencies, but CPSE and some other things that have caused some noise.
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But why is this possibly going to be a harder thing coming up in the next uh month or so and for who?
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So that is because of these type 13 entries for low-value shipments that originally they were under the de minimis rule, and they could basically come into the country without really any information passed to any government agency.
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And so there kind of was, I don't want to say a blind eye to it, but nobody had to submit any information.
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So so okay, real quick, type 13, what is this?
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What are we talking about?
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Oh, right.
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So these are the new entry type that was created for mail shipments coming into the United States.
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So historically, mail has been um a lot less scrutinized than the express, you know, when you would think, you know, the non-mail, let's just put it that way, the non-mail shipments that actually and the data is ending in customs database when it's not mail.
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And when it's male, they really don't have visibility into this data.
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And if and if it's not in customs, who else doesn't have visibility to the data then?
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The partner government agencies.
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The partner government agencies.
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Okay, so hold on a sec here.
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De Minimus went away last year.
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So why hasn't this been a thing for the last year in mail?
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Because it was delayed in the fact that you know everything was shut down when these types of things went into um play when De Minimus was taken out.
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And so we were given some time before type 13 was enacted, and that comes October 22nd.
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Okay, but this has been a problem let's call it uh a compliance requirement for commercial shipments, non-mail shipments for the last year.
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When De Minimus went away, that abruptly got got put on them for low-value shipments for the last year or so that the industry's been grappling with.
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And now mail's coming online to that, those same type of requirements, right?
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Yes.
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So and mail never had to have these requirements.
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They didn't need to have the information to submit to customs partner government agencies.
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And people have been scrambling just to even get the customs regulations requirements for these shipments.
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But partner government agencies, it's completely different.
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There's even more information that needs to be provided.
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I'm trying to under help me understand this a little bit because I I think we use PGA here in the US for partner government agency.
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I think it other countries might be Canada's as participant government agencies, or they use another acronym called OGA, which is other government agencies.
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Um I don't know how many countries use these.
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I don't, I'm not the expert on this at all.
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But I'm trying to understand like what's the point?
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Like, what's their function?
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Why can't it all just be customs and customs do everything?
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Yeah, because these government agencies, they each have their own realm that they're over.
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For instance, FDA, uh the Food and Drug Administration.
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A lot of people think they only cover food and drug, but they cover cosmetics, they cover radiation-admitting devices, stuff like that.
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Um, and why customs can't just handle it is because these government agencies were built to regulate this stuff to make it so it's safe for Americans.
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So FDA handles that stuff for food and drug, cosmetics, et cetera.
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CPSC does it for um consumer, it's the Consumer Safety Product Commission, and they handle it for like kids' toys, cribs, et cetera, stuff like that.
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Okay.
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So the the other government agency, you've got you've got different agencies focus on different types of things.
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And then where does customs come in?
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So customs is like a partnership with them.
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Customs, they hold the stuff that the government agencies ask them to hold.
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Uh, they they work in tandem, basically, together.
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Um, but uh the customs relies on the other government agencies to tell them, hey, what should we hold?
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What sh what isn't safe to come into the United States?
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So each of these government agencies are writing the rules that they care about, and customs is helping to enforce that.
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Correct.
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Correct.
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And that's where the partnership comes in.
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And so customs can't just unilaterally just make a bunch of decisions and say, ah, this government agency doesn't need to worry about this, doesn't need to worry.
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They're just there, they're basically taking the marching orders from the government agencies about what types of shipments to hold and how to operate.
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And they can work together and have you know collaborate on things, but CVP's really not the one in charge on on the other government agency requirements, correct?
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Okay.
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How many government agencies are there?
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There's about 50.
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50?
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Yeah.
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Oh, wow.
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Okay, what are the top five?
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All right.
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Let's talk about all 50 today.
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Right.
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Starting the top.
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What are the what are some of the top ones though?
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So, first off, I think it's important to to establish who is this going to impact the most on October October 22nd.
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It's going to be the shippers that have no idea what we're talking about right now, and they're expected to provide this data now somehow to either the postal provider they're shipping with.
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Or hey, and this could be talking also too if you're not shipping postal, right?
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You still you need to give it to the shipper so they have enough data to then clear the shipment into the United States, right?
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Without issue.
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So um to kind of set their expectations, and we've seen this in the non-mail environment.
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Aaron, what happens in the non-mail environment when a shipment doesn't have enough information?
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Like the from this partner, go, okay, let's what's it, what's an example of a good?
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Let's say it's uh, I don't know, a nutraceutical or something, and it's and the broker that's importing this, it does just doesn't have enough information.
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What actually happens?
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Yeah, and we're partners a lot of commercial carriers.
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And when the de minimis went away last year, and now all of a sudden government other government agency information was required, um shipments get held if they don't have it.
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And then they're out there making phone calls, sending emails, they're they're trying to find the information.
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They're typically going back to the shipper to get that information.
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And I think that's another aspect of this.
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We talked about how they might say what shipments to hold, but they also have requirements on information they need, right?
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So some shipments can just come in.
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Hey, you you fill out a commercial invoice, you've got to basically send it through.
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It goes through fine.
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That's probably generally that's a lot of shipments that that can come through depending on the type of goods.
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And then there's others that have certain requirements, but those requirements are all the same for every government agency, right?
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And all across the world.
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It's a wide range, a huge range, depending on if it's NITS and you need like make and model of uh car information, or if you need sometimes with CPSC, you need to put to say, hey, these kids' pajamas, are they fire retardant?
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And do you have a certification stating that they are?
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But but I'm sure all 50 government agencies get together in a room and talk to each other to make it really easy on the brokers and the shippers to be able to supply a standardized set of information, correct?
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I wish they did.
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I really, really wish they did, but they do not.
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All right then.
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What because so give me some examples of government.
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We talked about FDA.
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That's probably the biggest one.
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What's an FDA?
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The Food and Drug Administration.
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Food and Drug Administration.
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Really sorry, he doesn't like African.
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We're talking to I'm I'm in I'm a retailer in Canada.
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I'm a r I'm a retailer in Japan.
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I have no idea what FDA is.
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All right, okay.
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The team, the team knows when I hear an acronym, I get lit up a little bit.
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Okay, so the food and the food and drug administration.
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Yes.
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All right, there's there's that one.
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CPSC, Consumer Safety Product Commission, that does, you know, kids' toys, cribs.
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It even does some adult products as well, like uh cleaning supplies, stuff like that.
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Those are probably, from what I understand, those are really, especially when it comes to can consumer goods that are typically the low-value goods, those are the two biggest ones.
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Those are probably the biggest ones.
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Can I throw in a third that I think is a big one, especially in male?
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The pharmaceuticals, right?
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That way, that's NDA.
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That's FDA.
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That's FDA.
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Sub bullet, sub bullet.
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All right, yeah.
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Yeah, but uh, I mean, you even have fish and wildlife.
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So that one comes up, and a lot of people don't think it does for them.
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But for instance, if you're uh importing a say a wallet that has leather, but if it's cow leather, that's okay.
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If it's a domesticated animal, that's that's okay.
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But what if you have a crocodile uh skin leather?
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Uh, then it is a requirement uh with fish and wildlife to provide information on it.
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Okay.
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All right.
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So the all the oh man, all those Australian retailers selling the crocodile leather wallets.
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Okay.
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Well, I want to I want to actually I want to touch on this a little bit more.
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You've dealt with a lot of different PGAs in your career.
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A lot.
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Sorry.
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Partner government agencies in your career.
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Oh, yeah, we're gonna try to use nose at this point.
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You're fine.
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You're fine.
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All right.
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Um what are some of the weirdest things you've dealt with?
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Like what are some we are we've only talked about three of the 50, but like there's a lot of different agencies worried about I'm I can't even think of 50 different things that they would be out there.
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I mean, there's a lot, I mean uh TTVs, the tobacco and alcohol.
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I mean, some of the weird things though, like um I had an importer import hamster ovaries once for scientific purposes.
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Um and I mean that can be.
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There's an agency for that.
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Well, that's the fish and wildlife there, but you know, but I guess that's domesticated animals.
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But yeah, no, it comes into play there.
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I mean, there's lots of random stuff.
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Um let's see, what else is out there?
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Well, EPA chemicals.
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So this one, a lot of people don't think.
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EPA is the environmental protection agency.
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If you're importing a ballpoint pen, you actually have to certify that the chemical, the ink inside, um, is uh safe basically per Tosca regulations, the EPA.
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And because that ink can get on your skin.
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And so a lot of people don't think a ballpoint pen is regulated.
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Okay.
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Okay.
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Well, how do you how do you do that?
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What's the process for giving that information, whether it be the the the wallet or the ballpoint pen, or if it's pharmaceuticals or uh children's toys or whatever it is, like each agency has something they require.
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And how do you what's what's the actual process in submitting and giving that information so they're happy?
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So if you're the one, if you're the one shipping this, you need to have the information, for instance, um if it's a food item, you need to sometimes have the um FDA registrated a rate registration number for that manufacturer who manufactured that food.
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And that is not something that's public knowledge.
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Like medical devices, that manufacture information is actually public knowledge, but not for food.
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And so that stuff you kind of have to be able to find out that information before you ship it.
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Okay, so you find out the information before you ship it.
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How is it supplied?
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Yeah.
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And what like mechanism, because that needs to get to the broker, right?
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Now, when you're not in the I actually think this is really important, when you're not in the e-commerce environment, who's interacting with you as a broker?
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Because it's the world you lived in before.
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Who's your customer?
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The shipper.
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And the the shipper, right?
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They're the ones that are they know all these things, right?
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But they're the they're the ones that are actually shipping it.
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You're not interacting with an intermediary between you and the shipper.
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You have contact with the shipper and you know what they're importing, right?
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I I think that this is this is sometimes the the the the weird setup in in the e-commerce environment is there becomes a disconnect with the shipper and the broker, and that's the shipping carrier, right?
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And which has historically been fine.
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Uh-huh.
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Historically that's been well, has uh okay, two or more.
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Okay, because because there wasn't all these requ you know, there wasn't much being asked of of low value shipments coming into the U.
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You didn't need much.
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Yeah, but okay, but let's let's you just brought up though the fact that fine based on the current baseline, but even in the current baseline, in the non-mail environment, they are holding packages all the time.
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When I say previously, when we had De Minimus.
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Right, right.
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Yeah.
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Yes, when you had I see what you're saying.
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Yeah, before De Minimis, right?
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This is an absolute nightmare today in the non-mail environment.
00:14:50.080 --> 00:14:51.679
Just to be clear, right?
00:14:51.919 --> 00:15:07.679
So if you've been shipping mail and you've kind of been having a pass on some of these partner government agencies in terms of them just coming in, if you had been sending this within the commercial lane, you would have had these problems.
00:15:08.000 --> 00:15:20.240
And if you weren't, then either it was easily just derived right from what you said, right, on the commercial invoice, or honestly, the broker isn't being super honest and they might be inferring things themselves, right?
00:15:20.480 --> 00:15:30.320
But if you ship with like an express carrier who has their crap buttoned up, a UPS, a FedEx, or a DHL, if they don't know that thing's getting held.
00:15:30.960 --> 00:15:33.440
It's getting caged, and they're reaching out.
00:15:33.919 --> 00:15:38.080
And this is this is really a big problem that's trying to get solved right now.
00:15:38.320 --> 00:15:42.559
Um so I I do want to talk about now that data, right?
00:15:42.639 --> 00:15:50.000
So we talked how is it how is it it can be on the commercial invoice, it can be supplied directly to the broker when you're outside the mail, when you're outside the mail environment.
00:15:50.480 --> 00:15:55.519
Um this is a lot of like you're saying a lot of things.
00:15:55.600 --> 00:16:04.240
I'm listening to this, I'm a shipper, I'm like, how do I like how do we make how how can their life be made as easy as possible?
00:16:04.480 --> 00:16:07.679
And so something that can be done, right?
00:16:07.759 --> 00:16:18.320
Whether it's their whoever they're shipping with or they're, you know, let's say they're shipping with a a um a pulsal provider, maybe that pulse provider's asking them questions to kind of help them out.
00:16:18.720 --> 00:16:26.720
But as a broker, how much can you actually infer from what's received?
00:16:26.960 --> 00:16:32.799
Do you I mean like like how often are you able to be like, okay, yes, this is kind of obvious?
00:16:32.960 --> 00:16:35.519
And then other times, like, I have a I have more questions.
00:16:36.159 --> 00:16:42.879
So you can infer some from like the description and what it is, maybe being like, okay, this would be subject to FDA.
00:16:42.960 --> 00:16:46.080
I mean, if we have the HTS, then it flags for those type of things.
00:16:46.240 --> 00:16:49.279
Um, but within, for instance, say it flagged for FDA.
00:16:49.440 --> 00:16:58.559
We can infer completely because some items are classified on the same HTS that one could be a cosmetic, one could be um uh a food.
00:16:58.720 --> 00:17:02.000
I mean, there could be all sorts of different um things within that.
00:17:02.240 --> 00:17:02.799
Yeah, okay.
00:17:02.960 --> 00:17:19.759
So, Aaron, outside the United States, when it's an individual shipper right now, we've actually had a kind of a chance to to beta some of this, where someone downloads our mobile app, let's say in Japan, and they take a picture of the good, it figures out the HTS, right?
00:17:19.839 --> 00:17:22.240
They see kind of like how it's being classified.
00:17:22.640 --> 00:17:29.599
And what happens when it is going to be some type of partner government agency here?
00:17:29.680 --> 00:17:31.519
What what's the experience for the shipper?
00:17:32.079 --> 00:17:43.839
And give some numbers around um uh how smooth their experience is, um, how often like it can just be pretty much just one and done almost, and when it can't.
00:17:44.160 --> 00:17:56.880
Yeah, so um A, since you're inner the ship, I mean, let's be honest, a foreign shipper anywhere in the world is not going to be the foremost expert on US partner government agencies, right?
00:17:57.119 --> 00:18:02.400
So you've got to make sure you you you give them the information in a way that's understandable for them to easily uh ask.
00:18:02.480 --> 00:18:10.880
Now, you take that to a retail shipper and some you know low-volume shipper, just occasionally you know drop something off to the post office.
00:18:10.960 --> 00:18:13.119
You need to make it easy for them to go through the process.
00:18:13.279 --> 00:18:21.759
So you ask them some questions in really plain English or Spanish or French or Japanese, whatever their language is.
00:18:21.839 --> 00:18:22.640
So that's key.
00:18:22.720 --> 00:18:23.680
That's number one.
00:18:23.839 --> 00:18:26.400
And then um make it so it's easier to understand.
00:18:26.559 --> 00:18:32.160
And then also we can help to infer and say, hey, here's what we think, this is what we see based on um our expertise.
00:18:32.319 --> 00:18:33.359
Does this look right?
00:18:33.519 --> 00:18:37.759
And they can say, Yeah, that actually does look right, or no, let me change a few things.
00:18:38.000 --> 00:18:40.400
And we're right about 85% of the time.
00:18:40.480 --> 00:18:42.000
And they say, Yeah, that actually looks right.
00:18:42.079 --> 00:18:56.640
And so it makes it within seconds, they can they can answer these questions, give the information, and this has been some awesome data leading up to because you know, even though it's still going on a spreadsheet right now, this data, so but we're already doing what we should be as a broker, right?
00:18:56.720 --> 00:18:58.799
Which is asking these questions to the shipper.
00:18:59.519 --> 00:19:02.319
What's what's incredible about this data, it's two things.
00:19:02.400 --> 00:19:10.240
One, 85% of the time, we are able to present to them, like, here's based on you took a photo, I can get a lot, right?
00:19:10.319 --> 00:19:16.559
Like we can we can start inferring a lot of information about the good, and they can attest and say, Yep, that's accurate.
00:19:16.799 --> 00:19:19.519
So I think that you know that's an that's an incredible number.
00:19:19.839 --> 00:19:27.599
The invert is also crazy, which is, and I think it's 80, 86, 14 is kind of the numbers, but you're you're closer.
00:19:27.920 --> 00:19:30.079
On the 14%, give or take.
00:19:30.480 --> 00:19:30.960
Give or take.
00:19:31.039 --> 00:19:36.160
You're rounding on that other 14%, it means we didn't infer correctly.
00:19:36.319 --> 00:19:38.480
We have a team of data scientists that do this.
00:19:38.960 --> 00:19:58.160
And the reason that's important is if a broker says they can do it 100% of the time, either they have a team of data scientists better than us that are, you know, and also probably better than something like uh I don't know, anything else in the world, um, or they're not doing it properly.
00:19:58.319 --> 00:20:08.319
Because or Angela, do you think a broker can infer 100% of the time what's uh what's actually that is based on either a picture or the description or anything like that?
00:20:08.640 --> 00:20:17.759
No, they can't, and especially um, even if it's inferred that it's an FDA, FDA requires the manufacturer information and they cannot just provide anything.
00:20:17.839 --> 00:20:23.279
They can be like, oh yeah, the manufacturer is my sister, put her name and address.
00:20:23.599 --> 00:20:35.519
Because if they are putting that information and it's incorrect, say the broker inferred that and it's incorrect, FDA flags it, exams it, and says, Nope, this is wrong.
00:20:35.680 --> 00:20:37.279
Give me the required information.
00:20:37.920 --> 00:20:38.559
Yep.
00:20:38.960 --> 00:20:43.920
So, okay, so we you you you can't always just infer, so you got to get that data.
00:20:44.079 --> 00:20:53.200
And now it's all about okay, now how do you build this experience out for um uh for these these retailers?
00:20:53.359 --> 00:20:56.240
So now now we're kind of in like how do I comply, right?
00:20:56.319 --> 00:21:13.039
We've talked about what they are, um uh the difficulty, and you know, really just kind of actually before I get how I comply, because I've missed a bullet, we need to talk about pharmaceuticals, and then let's get to the compliance part.
00:21:13.359 --> 00:21:19.599
And the reason I uh Aaron, why is why do you think pharmaceuticals is like a carve out here discussion?
00:21:20.559 --> 00:21:27.119
Well, pharmaceuticals are very, very tightly controlled when it comes to the US.
00:21:27.279 --> 00:21:30.640
I mean, look, how much how much has fentanyl been in the headlines?
00:21:31.039 --> 00:21:31.200
Right?
00:21:31.359 --> 00:21:35.920
So, but in general, all of this stuff is very, very tightly regulated.
00:21:36.799 --> 00:21:42.960
And so if you if you look historically, UPS has been fined$40 million.
00:21:44.480 --> 00:21:47.440
Uh FedEx had a whole lawsuit they went through.
00:21:47.519 --> 00:21:52.000
They ended up winning, but it was like a civil lawsuit against them in into the billions.
00:21:52.079 --> 00:21:53.920
Um, that luckily they won.
00:21:54.160 --> 00:21:58.960
Um, that says, Hey, you as the broker clearing this, you need to do everything right.
00:21:59.279 --> 00:22:10.240
Um And it's interesting how much pharmaceuticals go in direct to consumer through the mail, but aren't going through the commercial channel.
00:22:10.400 --> 00:22:11.279
Why is that?
00:22:11.599 --> 00:22:13.680
Oh, it's because they can.
00:22:14.000 --> 00:22:14.720
Because they can.
00:22:14.880 --> 00:22:19.920
Because they can because it's coming in outside the view of these other government agencies.
00:22:20.240 --> 00:22:24.640
I was going to say it's the path of least resistance, but it's more like the path of no resistance.
00:22:26.079 --> 00:22:30.160
And so it's this this is this is about to get closed, right?
00:22:30.240 --> 00:22:34.000
We were talking to a postal operator the other day, and they're like, I get it.
00:22:35.200 --> 00:22:42.559
And we're going to jump on a lot of calls with their shippers, but I get it that there's a lot of things that are shipping that is non-compliant.
00:22:42.799 --> 00:22:55.119
So I think one, if you sh sell pharmaceuticals online and a lot of things with FDA, but there is a chance you won't be able to do it anymore.
00:22:55.599 --> 00:22:56.799
There is there is a chance, right?
00:22:56.880 --> 00:22:59.839
That you are actually shipping something that cannot come in, period.
00:23:00.559 --> 00:23:02.720
And then there's a chance you can.
00:23:02.799 --> 00:23:05.759
And in the in the world of pharmaceuticals, let's say I can.
00:23:06.160 --> 00:23:08.799
What are what are what now is required?
00:23:08.960 --> 00:23:16.720
What are some examples of um whether it's prescription drugs, non-prescription, uh, I don't know, whatever else is on your mind, Angela.
00:23:16.799 --> 00:23:25.599
What what are so how do I now actually ship these types of goods into the United States?
00:23:25.920 --> 00:23:30.160
And we already, you know, we'll talk about how to get the data, but I'm more interested in like what data is needed.
00:23:30.240 --> 00:23:31.359
What do they need to do?
00:23:31.839 --> 00:23:32.160
Yeah.
00:23:32.319 --> 00:23:43.039
So with pharmaceuticals in general, especially prescription, it gets really complicated because for there is a personal use exemption with FDA.
00:23:43.279 --> 00:23:56.640
So they still need to supply, hey, a letter from the consumer here in the US saying it is for personal use, and here's my doctor's information that um wrote this prescription for me.
00:23:56.960 --> 00:24:00.400
And then FDA can even request that prescription.
00:24:00.640 --> 00:24:02.880
And that is not something a broker can ever infer.
00:24:02.960 --> 00:24:04.640
We we can't infer a prescription.
00:24:05.119 --> 00:24:07.279
And so that needs to be provided.
00:24:07.440 --> 00:24:20.319
Also, right now, as the regulations stand, if that drug that's a prescription drug, is already sold in the United States, then it cannot come in even under the personal use exemption.
00:24:22.000 --> 00:24:22.319
Okay.
00:24:22.559 --> 00:24:26.400
So it has to be a drug that is currently not for sale.
00:24:26.640 --> 00:24:27.759
That's the starting point.
00:24:28.079 --> 00:24:30.559
If it's not available inside the United States, okay.
00:24:31.200 --> 00:24:33.440
But you have a prescription.
00:24:33.519 --> 00:24:38.480
So now we're talking from the standpoint of I'm inside the United States, but I have a prescription.
00:24:38.640 --> 00:24:46.160
What happens though if like it is available and I I think I probably know the answer actually based on what you said, but it is in the United States, it is available.
00:24:46.240 --> 00:24:52.640
I'm traveling here and my doctor's overseas, like what what and I need my prescription.
00:24:52.960 --> 00:24:57.680
So there is a foreign visitor um exemption where if you are not based in the I didn't know the answer.
00:24:57.759 --> 00:24:58.000
This is good.
00:24:58.079 --> 00:24:58.160
Okay.
00:24:58.640 --> 00:24:59.039
It's okay.
00:24:59.200 --> 00:25:19.519
If you are not based in the United States um and you come, say, for a trip for two weeks and you forgot your medication, well, if you're able to then provide that information, you can get the prescription that is already sold here in the US, um, as long as you have that prescription from the foreign entity, the foreign doctor, and you're able to uh ship that into the United States if you're a visitor.
00:25:19.920 --> 00:25:26.240
So lots of paths of like questions and answers that leads to yes or no's, right?
00:25:26.799 --> 00:25:27.680
Or documentation.
00:25:27.759 --> 00:25:27.920
Yeah.
00:25:28.160 --> 00:25:28.319
Right.
00:25:28.480 --> 00:25:34.880
Yes, yes or no's on the documentation, yes or no's on the import, and yes or no on okay, what kind of documentation do I need?
00:25:35.119 --> 00:25:38.559
Um and this is a lot of things that we're we're doing right now in the mobile app, right?
00:25:38.640 --> 00:25:42.160
At least from the the the individual shipper's perspective overseas.
00:25:42.240 --> 00:25:47.200
So if your grandma's shipping you something into the US, we'll make your life as easy as possible.
00:25:47.440 --> 00:25:49.680
Um that's fascinating.
00:25:49.920 --> 00:26:07.759
Yeah, now I one other interesting thing about this is um, you know, you would sometimes we we just think, oh, well, the FDA clearly has been thinking about this on all these low-value mail shipments and everything, you know, in this whole new process.
00:26:07.839 --> 00:26:12.319
And they're they're gonna make sure they have the most practical, reasonable requests, right?
00:26:12.960 --> 00:26:19.440
Well, I wish that was the case, but I'm not sure they fully grasp the concept of what is in the mail environment.
00:26:19.759 --> 00:26:27.359
And I think that's key is they're learning too, because what they have is all the regulations they built for a different type of environment.
00:26:27.519 --> 00:26:34.640
You know, this is this is goods coming into pharmacies and you know, higher value shipments that are cleared with a broker.
00:26:34.799 --> 00:26:37.279
Like there, there's a very controlled process with that.
00:26:37.519 --> 00:26:44.960
But this direct-to-consumer low-value shipment mail environment um is something that they they there's a lot of unknowns for them as well.
00:26:45.039 --> 00:26:48.000
And this isn't just the FDA, this is this is all the government agencies.
00:26:48.400 --> 00:26:50.160
Yeah, none of them had the data before.
00:26:50.319 --> 00:26:55.440
None of them had insight into what was coming because nobody ever had to submit something to them.
00:26:55.759 --> 00:26:57.039
Let's talk about that.
00:26:57.359 --> 00:27:02.799
A year ago, when there was a de minimis, what was the clearance process like on a low value shipment?
00:27:03.119 --> 00:27:04.559
It was completely easy.
00:27:04.640 --> 00:27:11.599
You didn't really have to, I mean, you had to pay the duties and taxes if there happened to be some, but um you really it would just go through.
00:27:11.839 --> 00:27:14.640
There was nothing to partner government agencies, there was nothing provided.
00:27:15.119 --> 00:27:16.160
This is type 86, right?
00:27:16.319 --> 00:27:17.039
Yeah, type 86.
00:27:17.279 --> 00:27:22.160
So these government agencies have been completely blind to low value shipments effectively for years.
00:27:22.400 --> 00:27:22.559
Right.
00:27:22.799 --> 00:27:27.839
Then they started getting some information a year ago on the commercial side, and now mail is a whole new thing.
00:27:28.480 --> 00:27:30.079
Commercial ended up with a huge problem.
00:27:30.160 --> 00:27:30.480
Uh-huh.
00:27:30.720 --> 00:27:38.640
And what's crazy is okay, commercial has a huge problem, but Aaron, and that's that's with these partner government agency shipments.
00:27:38.720 --> 00:27:41.759
They have they do it, they have a big problem because they're trying to figure this out.
00:27:42.160 --> 00:27:44.960
But where's the majority of this volume going through?
00:27:45.200 --> 00:27:46.000
Well, the mail.
00:27:46.160 --> 00:27:50.000
So how big's the problem going to be in mail come October 22nd?
00:27:51.119 --> 00:27:51.519
Huge.
00:27:51.839 --> 00:27:52.720
It's gonna be big.
00:27:53.279 --> 00:28:06.799
And I think uh we'll it'll be we don't know how big, but because I think customs is trying not to know you don't want to like have a standstill on everything, but it's gonna be an absolute cluster.
00:28:06.880 --> 00:28:08.480
It's gonna be an absolute mess.
00:28:09.759 --> 00:28:12.720
And so there's a lot of like everybody's trying to figure this out.
00:28:12.799 --> 00:28:14.160
Like, is there other easy buttons?
00:28:14.319 --> 00:28:16.079
Like, like I I don't I don't blame.
00:28:16.240 --> 00:28:19.440
I've I'm a if I'm a shipper, I'm like, what's my easy button?
00:28:19.599 --> 00:28:19.759
Right?
00:28:20.240 --> 00:28:25.039
If I'm a post postal operator, I'm like, what what easy buttons do we got here?
00:28:25.359 --> 00:28:31.839
With CPSE, right, which is the the consumer consumer product safety conditions.
00:28:32.319 --> 00:28:34.960
I had to say the acronym because I don't even know what the other thing means.
00:28:35.279 --> 00:28:39.839
All right, so with the with okay, I'm just gonna use CPSE.
00:28:39.920 --> 00:28:47.839
So with CPSE, there's um I Okay.
00:28:48.640 --> 00:29:01.039
There's like a regist okay, a certificate and identifiers like what what what's required on CPSE and then can it be reused on every single shipment, like that information, or like how does it how does it work?
00:29:01.519 --> 00:29:03.039
So it there's two different ways.
00:29:03.200 --> 00:29:12.160
You could set up a registry um with that uh to be able to supply the information ahead of time, and then yes, provide these three identifiers to your broker to clear it.
00:29:12.240 --> 00:29:15.839
And if you're shipping that same item over and over, you can do some of that.
00:29:16.240 --> 00:29:22.720
But um it really matters if you have the information first and submit for that certificate to prove that it is safe.
00:29:23.039 --> 00:29:25.920
And that certificate comes from CPSC, right?
00:29:26.079 --> 00:29:34.559
Yes, yeah, you you submit you're submitting like testing information, all that stuff, and getting in a reference number for your product that then you can use on all your shipments of that product.
00:29:34.640 --> 00:29:35.039
Is that the same?
00:29:35.200 --> 00:29:36.480
Of that specific product, yep.
00:29:36.799 --> 00:29:37.519
Okay, that makes sense.
00:29:37.759 --> 00:29:55.680
And so I think generally that as much as we want easy buttons, we the best thing we can do is provide easy processes, as easy as possible, versus okay, we can just infer be or like, yeah, you there they you are gonna have to provide information.
00:29:56.240 --> 00:29:56.720
100%.
00:29:57.200 --> 00:29:58.720
Yeah, but you can that's unique.
00:29:58.960 --> 00:30:04.240
Why can't we oftentimes make crap up and then just to get it through as long as nobody else questions?
00:30:04.720 --> 00:30:07.839
Hey, hey Aaron, you actually you can want me to give you some examples?
00:30:08.079 --> 00:30:08.240
Yeah.
00:30:08.480 --> 00:30:09.119
So all right, yeah.
00:30:09.200 --> 00:30:15.759
So the I think that the you know, I you know I think there's that broker got shut down.
00:30:15.920 --> 00:30:16.319
Hold on.
00:30:16.480 --> 00:30:18.079
There's another one that I think is getting fine.
00:30:18.160 --> 00:30:25.359
Aaron, you were just at the uh how well is this going for people that are it's not going well, and this is actually that type of mentality.
00:30:26.000 --> 00:30:32.160
And honestly, there's a lot that have been getting away with it, but it's changing.
00:30:32.240 --> 00:30:46.799
And in fact, that that's where the theme was as far as CVP is concerned, is like, hey, if we come asking, or if another government agency comes asking for more information, or to say, How did you get this information?
00:30:47.279 --> 00:30:50.960
They're really fed up with the answer of like I I I I don't know.
00:30:51.200 --> 00:30:52.880
Yeah, um, I just made it up.
00:30:52.960 --> 00:30:53.599
I I don't know.
00:30:53.759 --> 00:31:02.000
And instead of saying, Oh, we got a from this shipper and this is their documentation, here's all this extra information that that backs up our claim.
00:31:02.160 --> 00:31:03.440
That goes over well, right?
00:31:03.599 --> 00:31:04.960
And that's the expectation.
00:31:05.119 --> 00:31:12.799
But if none of that's there, if it's hollow behind that that initial entry, that's where there's a big problem, and that's where a lot of people get are getting shut down.
00:31:13.039 --> 00:31:18.160
If you're if you're a US broker, my message would be get ready to get graded on a curve, right?
00:31:18.319 --> 00:31:22.319
Hey, this is like uh um natural selection here.
00:31:22.480 --> 00:31:26.319
If you we're all running, Aaron, I'm out running you, and the bear's getting you, right?
00:31:26.400 --> 00:31:33.920
So it's like you just need to be do as good as you be, you bet not as not just as good as you can, you need to be better than the other guy, right?
00:31:34.000 --> 00:31:35.599
Because this is going to happen.
00:31:35.759 --> 00:31:38.960
And when customs walks in and they're like, this is reasonable.
00:31:39.039 --> 00:31:39.920
What are you talking about?
00:31:40.079 --> 00:31:42.079
I have this data from somebody else.
00:31:42.319 --> 00:31:43.680
What are you going to say?
00:31:44.079 --> 00:31:56.400
And and this is it's it's I know this is problematic, and and we're all trying to figure this out as brokers in the industry, but I can't think of any other way, better way to say it than you better be better than not just the next guy, it's a lot of the other guys, right?
00:31:56.480 --> 00:32:01.200
Like you you be because nobody's been great until now.
00:32:01.359 --> 00:32:02.880
I'm sorry, no one's been great yet.
00:32:02.960 --> 00:32:07.359
And so you we gotta figure out what group good looks like and execute.
00:32:08.240 --> 00:32:11.200
Okay, now back to the individual shippers.
00:32:11.279 --> 00:32:14.240
I'm a business Aaron, and so these questions are for you.
00:32:14.640 --> 00:32:18.480
Uh, and we don't want to talk too much about kind of what we do, but I think this is kind of relevant.
00:32:18.559 --> 00:32:18.720
Yeah.
00:32:19.039 --> 00:32:25.519
Um, because we have tons of shippers in Canada, Japan, Australia, right?
00:32:26.079 --> 00:32:27.279
This is coming.
00:32:27.839 --> 00:32:35.119
I have a massive catalog, or I have, you know, I sell online, I'm subject to one of the partner government agencies.
00:32:35.359 --> 00:32:36.559
What's my experience like?
00:32:36.720 --> 00:32:38.400
What how do you make my life easy?
00:32:38.640 --> 00:32:40.319
Because I don't use a mobile app.
00:32:40.400 --> 00:32:41.359
I mean, we kind of talked about that.
00:32:41.440 --> 00:32:43.440
So the how on the mobile app was kind of explained.
00:32:43.519 --> 00:32:47.680
But what happens if I'm I'm I'm sending thousands and thousands of shipments a day?
00:32:47.920 --> 00:32:55.279
Yeah, so uh let's talk about the the one that's workable but not ideal, uh, which is hey, I might get an email.
00:32:55.519 --> 00:33:00.640
Uh that you know, I'll send you an email that says, Hey, I need more information on this particular product.
00:33:00.720 --> 00:33:03.519
So you can ship, and maybe that a lot of your products don't need extra information.
00:33:03.759 --> 00:33:04.480
So it's in transit.
00:33:04.799 --> 00:33:12.480
You may never hear anything, but on something that's in transit, I'm gonna get an email or gonna send you an email and a message, say, hey, we need some information here.
00:33:12.640 --> 00:33:12.960
Okay.
00:33:13.279 --> 00:33:17.759
Um the cool thing is you can supply that information and we can save it for the next time that product ships.
00:33:17.920 --> 00:33:18.480
That's great.
00:33:18.720 --> 00:33:22.960
But wouldn't you like to be ahead of this instead of getting spammed with a whole bunch of uh sure?
00:33:23.039 --> 00:33:25.200
So yeah, so how do you how do you get ahead of it?
00:33:25.359 --> 00:33:28.319
Because I think that's fine for maybe some smaller shippers, right?
00:33:28.799 --> 00:33:30.559
But I want to get ahead of it, you know.
00:33:30.640 --> 00:33:35.440
Um I sell on Shopify, I sell on eBay, um, I sell on Etsy.
00:33:36.000 --> 00:33:37.200
How do how do what do I do?
00:33:37.519 --> 00:33:42.799
This is the easiest thing for you to do, and this is honestly how it works in the commercial environment.
00:33:42.960 --> 00:33:48.400
I can I can talk about that second here, with but is just catalog everything ahead of time.
00:33:48.640 --> 00:33:54.720
Our tools go through and screen it and ask for the questions ahead of time, and then and then you're then when that product ships, you're good.
00:33:54.799 --> 00:34:09.199
And the the best part is how we build that catalog, if you're on Shopify eBay, Etsy, you know, there's there's a whole bunch of channels, you can connect your store, we can pull all of that in dynamically, screen it, ask the questions on the on the products where we need more information, and you're done.
00:34:09.360 --> 00:34:15.599
Um, if we don't have, if you have a custom thing, uh site or something we could you can upload a CSV file of your catalog.
00:34:15.840 --> 00:34:16.719
Or even time to the API.
00:34:16.800 --> 00:34:17.280
We've had shippers.
00:34:17.599 --> 00:34:20.000
We had a pharmaceutical customer customer recently, right?
00:34:20.320 --> 00:34:23.840
So okay, let me tell you how this works and how awesome it is.
00:34:24.079 --> 00:34:27.840
There was there was a recent example of, and I think it was pharmaceuticals, right?
00:34:28.000 --> 00:34:29.519
Um the one that Nick was dealing with.
00:34:29.840 --> 00:34:30.239
Yeah.
00:34:30.400 --> 00:34:39.440
Um, that there we were getting if we didn't have enough information that was coming in from the postal operator, and they were getting, I think, an extra 100% tariff.
00:34:39.519 --> 00:34:42.079
Like it was, it was pretty, pretty, pretty brutal.
00:34:42.320 --> 00:34:44.400
And so the shipper's upset, right?
00:34:44.480 --> 00:34:45.679
We don't want to classify it wrong.
00:34:45.920 --> 00:34:48.239
Like we want to do it right, but we're missing data.
00:34:48.480 --> 00:34:51.039
And so the customer's like, Do you got an API?
00:34:51.280 --> 00:34:51.840
What happened?
00:34:52.079 --> 00:34:53.039
They signed the API.
00:34:53.679 --> 00:34:54.480
How'd it work?
00:34:54.960 --> 00:34:55.840
Very well.
00:34:56.159 --> 00:34:57.199
We connected, right?
00:34:57.280 --> 00:34:59.840
So we they connected the shipment with the tracking number.
00:34:59.920 --> 00:35:10.079
So they told us, hey, the shipment, here's the shipment with the tracking number, and they gave us all the additional data on every single shipment because the data that's coming through the pulseal stream is incomplete.
00:35:10.400 --> 00:35:12.639
We completed it and it worked.
00:35:12.880 --> 00:35:14.480
Yeah, and I think that brings up a good point.
00:35:14.639 --> 00:35:18.320
There is the you gotta get this data just to be compliant and not get in trouble.
00:35:18.559 --> 00:35:19.519
Okay, that's one.
00:35:19.679 --> 00:35:24.239
But there's also a whole nother set of data that can be captured to reduce tariffs.
00:35:24.480 --> 00:35:25.360
What else reduces tariffs?
00:35:25.440 --> 00:35:25.920
Look, you know what?
00:35:26.000 --> 00:35:43.519
I know we talked about partner government agencies, but really quick, and it there's like still in aluminum the 232 tariffs, uh, you know, getting that type of that content information will uh we'll get uh FTAs, you know, if you want to free trade agreements to to give your certificate of origin and those that type of information so we can you know get duty-free treatment.
00:35:44.000 --> 00:35:55.039
All of those things are documentation requirements, data requirements that are either those are for an advantage from a cost perspective.
00:35:55.199 --> 00:36:15.440
Um, and then there's then there's the compliance side of it too, with the other government agencies, but it's all really the same problem uh of just hey, the more information, the more data you get, the more compliantly you can clear it, and the better your stuff's gonna be clearing because you're gonna set a precedent that you're a compliant shipper, um, and then you're gonna you're gonna get the best possible tariff rates out there.
00:36:15.599 --> 00:36:16.079
Yeah.
00:36:16.480 --> 00:36:17.119
This is awesome.
00:36:17.679 --> 00:36:19.519
Anything else that we that I might have missed?
00:36:19.679 --> 00:36:20.880
Any questions, Aaron?
00:36:22.000 --> 00:36:23.360
I still, okay.
00:36:24.079 --> 00:36:30.079
Craziest thing that you've seen with with PGAs or just clearance brokerage in general, just the most oddball thing.
00:36:30.159 --> 00:36:30.960
I'm putting you on the spot.
00:36:31.039 --> 00:36:33.360
We didn't we did not prep her ahead of time for this.
00:36:33.440 --> 00:36:36.159
So I'm gonna ramble for a few more seconds while she starts thinking.
00:36:36.320 --> 00:36:38.239
I just want to hear a cool story.
00:36:38.639 --> 00:36:39.599
A cool story.
00:36:39.679 --> 00:36:42.320
Well Or a crazy weird one that you wouldn't even think of.
00:36:42.559 --> 00:36:42.880
Okay.
00:36:43.360 --> 00:36:57.280
So uh I guess one thing that I could think of that I mean, I guess it doesn't have to do specifically with partner government agencies necessarily, but um, like there's random regulations that come up with uh any import into the US.
00:36:57.360 --> 00:37:01.280
And sometimes these regulations are have been old standing and they still apply.
00:37:01.440 --> 00:37:11.280
But one thing that I kind of bring up that kind of blows people's mind is did you know that if you are importing a switchblade into the country, that you actually have to be a one-armed man?
00:37:11.599 --> 00:37:16.000
Because nobody else can import a switchblade into the country unless you are a one-armed man.
00:37:16.639 --> 00:37:17.440
Hold on.
00:37:18.800 --> 00:37:22.400
How do you how do you know as a broker?
00:37:22.559 --> 00:37:24.880
How would you know that it's a one-armed picture?
00:37:25.199 --> 00:37:28.480
There's no way you would know unless I don't know, you have to ask them right?
00:37:28.719 --> 00:37:29.599
Yes, you do have to.
00:37:30.000 --> 00:37:31.440
It's not something that I can infer.
00:37:31.519 --> 00:37:32.320
Are you a one-armed?
00:37:32.480 --> 00:37:33.280
I mean, how do you infer that?
00:37:33.519 --> 00:37:40.000
So if we see a switch blade coming in that we're supposed to clear, we're going to have to ask.
00:37:40.480 --> 00:37:42.079
Outreach to the receipt to the recipient.
00:37:42.480 --> 00:37:43.679
Do you only have one arm?
00:37:44.159 --> 00:37:46.559
Did you did you tell the engineers this needs to get built in yet?
00:37:46.719 --> 00:37:51.920
Because it seems like that's or a woman, you know, I'd assume.
00:37:52.079 --> 00:37:54.400
So that's wild.
00:37:54.639 --> 00:37:55.760
I was that's a good example.
00:37:55.840 --> 00:37:57.280
But it actually kind of makes sense.
00:37:57.760 --> 00:38:02.559
If it's the story we're telling, like there's certain things that can't come in unless.
00:38:02.800 --> 00:38:03.119
Unless.
00:38:03.199 --> 00:38:03.440
Uh-huh.
00:38:03.519 --> 00:38:03.760
Right?
00:38:03.840 --> 00:38:05.920
And now you have to be able to get the unless.
00:38:06.159 --> 00:38:06.880
The unless.
00:38:07.119 --> 00:38:08.559
And that's true.
00:38:08.800 --> 00:38:09.119
That's in.
00:38:09.360 --> 00:38:13.840
Yeah, so there's a lot of no's and there's a lot of it sounds like wild exceptions.
00:38:14.000 --> 00:38:14.239
Yes.
00:38:14.480 --> 00:38:18.880
I love that we get to end the podcast with a one R man story.
00:38:19.280 --> 00:38:19.679
All right.
00:38:19.920 --> 00:38:21.599
Looking forward to uh to another one.
00:38:21.679 --> 00:38:23.440
So hopefully hopefully this was helpful.
00:38:23.599 --> 00:38:24.480
We'll do a little bit better.
00:38:24.559 --> 00:38:26.400
Feel free to ask some questions in the comments.
00:38:26.480 --> 00:38:29.760
Um, and uh we'll we'll jump in and and reply to some of those.
00:38:29.840 --> 00:38:31.039
So thanks for thanks for listening.
00:38:31.199 --> 00:38:32.000
Thanks, Angela.
00:38:32.159 --> 00:38:32.960
Thank you.
00:00:06.559 --> 00:00:10.800
Hey, welcome back to another episode of the Decoding Cross Border E-Commerce Podcast.
00:00:10.880 --> 00:00:16.160
I have the familiar face of Aaron here with me, but also, Aaron, today we have Angela Mackey.
00:00:16.399 --> 00:00:21.199
Angela is our corporate customs board broker for Zonos.
00:00:21.600 --> 00:00:29.280
And uh uh we're gonna talk today about partner government agencies, PGAs.
00:00:29.679 --> 00:00:31.679
Why don't you just use the PGA?
00:00:31.839 --> 00:00:35.600
Like the acronym, the acronym is because I don't I'm not a golf.
00:00:35.840 --> 00:00:36.240
Wait.
00:00:36.479 --> 00:00:37.520
Don't you love acronyms?
00:00:37.679 --> 00:00:39.920
Oh, you can acronym P partner Government Okay, yeah.
00:00:40.159 --> 00:00:41.200
And it's not confusing at all.
00:00:41.359 --> 00:00:43.840
Like a lot it's the only PGA possible.
00:00:44.000 --> 00:00:44.479
Yeah, yeah.
00:00:44.640 --> 00:00:49.600
When you search for it, except for golf and what other things that that that come up when you when you search for it.
00:00:49.759 --> 00:00:52.159
But I'm gonna start this off real quick though.
00:00:52.320 --> 00:00:53.039
Talk about golf.
00:00:53.119 --> 00:00:56.479
I went miniature golfing with my family a couple weeks ago.
00:00:56.640 --> 00:00:56.880
Chaos.
00:00:57.119 --> 00:00:57.679
That's a lot of kids.
00:00:57.759 --> 00:00:57.920
Absolutely.
00:00:58.079 --> 00:00:58.399
Oh, yeah.
00:00:59.600 --> 00:01:00.479
Little four-year-old running around.
00:01:00.799 --> 00:01:01.439
What's the number of kids?
00:01:02.640 --> 00:01:02.960
Eight kids.
00:01:03.200 --> 00:01:03.840
Eight kids, okay.
00:01:03.920 --> 00:01:08.079
I can so that so they you you're renting the whole mini golf course.
00:01:08.400 --> 00:01:09.200
Pretty much, pretty much.
00:01:09.280 --> 00:01:09.519
Yeah.
00:01:09.760 --> 00:01:12.000
But I actually learned something in the process.
00:01:12.319 --> 00:01:16.400
Did you know miniature golfers never get anything done?
00:01:17.120 --> 00:01:17.920
Do you know why?
00:01:18.079 --> 00:01:18.319
No.
00:01:18.480 --> 00:01:18.719
No.
00:01:18.879 --> 00:01:20.480
They have no drive.
00:01:22.159 --> 00:01:22.239
Okay.
00:01:23.359 --> 00:01:26.959
Apparently there's a podcast I didn't laugh at when you're jokes, but I laughed at that one.
00:01:27.040 --> 00:01:27.840
So you're welcome.
00:01:28.079 --> 00:01:28.319
All right.
00:01:28.560 --> 00:01:29.599
Angela, okay.
00:01:29.760 --> 00:01:31.840
Uh tell us a little bit about yourself, your background.
00:01:32.400 --> 00:01:42.239
Um, and uh uh yeah, I think it's helpful because we'd like to bring you on every once in a while to talk uh talk a little bit of shop around customs brokerage into the United States.
00:01:42.319 --> 00:01:43.359
So sure, yeah.
00:01:43.519 --> 00:01:47.120
Um so I've been in this industry for a little over 10 years.
00:01:47.359 --> 00:01:49.920
Um I am a licensed customs broker.
00:01:50.079 --> 00:01:52.640
I have been a licensed customs broker since 2021.
00:01:52.719 --> 00:01:54.239
I passed that dang exam.
00:01:54.400 --> 00:01:55.920
It's uh hard and long.
00:01:56.239 --> 00:02:03.120
But uh yeah, and I've been doing that for the past 10 years and uh I've been really enjoying it.
00:02:03.519 --> 00:02:05.760
Well, we're uh we're grateful to have you here.
00:02:05.840 --> 00:02:09.199
And uh thanks for thanks for moving to the sunny side of the state.
00:02:09.439 --> 00:02:15.039
Uh Angela uh in her previous life worked in northern Utah and has moved down to southern Utah.
00:02:15.280 --> 00:02:20.639
So, all right, we're we're excited to get into this mostly because why is this a topic right now?
00:02:20.719 --> 00:02:21.520
Why does this even matter?
00:02:21.680 --> 00:02:23.840
I mean, these these agencies have been around a long time.
00:02:24.000 --> 00:02:31.680
I mean, there's been a little more um, and we'll talk about the different agencies, but CPSE and some other things that have caused some noise.
00:02:31.919 --> 00:02:38.479
But why is this possibly going to be a harder thing coming up in the next uh month or so and for who?
00:02:39.360 --> 00:02:55.840
So that is because of these type 13 entries for low-value shipments that originally they were under the de minimis rule, and they could basically come into the country without really any information passed to any government agency.
00:02:56.159 --> 00:03:01.759
And so there kind of was, I don't want to say a blind eye to it, but nobody had to submit any information.
00:03:02.000 --> 00:03:04.479
So so okay, real quick, type 13, what is this?
00:03:04.560 --> 00:03:05.199
What are we talking about?
00:03:05.439 --> 00:03:06.000
Oh, right.
00:03:06.240 --> 00:03:11.520
So these are the new entry type that was created for mail shipments coming into the United States.
00:03:11.840 --> 00:03:30.159
So historically, mail has been um a lot less scrutinized than the express, you know, when you would think, you know, the non-mail, let's just put it that way, the non-mail shipments that actually and the data is ending in customs database when it's not mail.
00:03:30.319 --> 00:03:33.599
And when it's male, they really don't have visibility into this data.
00:03:33.680 --> 00:03:37.439
And if and if it's not in customs, who else doesn't have visibility to the data then?
00:03:37.759 --> 00:03:38.800
The partner government agencies.
00:03:39.039 --> 00:03:39.840
The partner government agencies.
00:03:40.000 --> 00:03:40.960
Okay, so hold on a sec here.
00:03:41.680 --> 00:03:43.439
De Minimus went away last year.
00:03:43.520 --> 00:03:47.520
So why hasn't this been a thing for the last year in mail?
00:03:48.000 --> 00:03:55.360
Because it was delayed in the fact that you know everything was shut down when these types of things went into um play when De Minimus was taken out.
00:03:55.439 --> 00:04:01.599
And so we were given some time before type 13 was enacted, and that comes October 22nd.
00:04:01.919 --> 00:04:10.639
Okay, but this has been a problem let's call it uh a compliance requirement for commercial shipments, non-mail shipments for the last year.
00:04:10.960 --> 00:04:18.000
When De Minimus went away, that abruptly got got put on them for low-value shipments for the last year or so that the industry's been grappling with.
00:04:18.079 --> 00:04:21.519
And now mail's coming online to that, those same type of requirements, right?
00:04:21.839 --> 00:04:22.160
Yes.
00:04:22.319 --> 00:04:25.839
So and mail never had to have these requirements.
00:04:25.920 --> 00:04:30.399
They didn't need to have the information to submit to customs partner government agencies.
00:04:30.560 --> 00:04:36.639
And people have been scrambling just to even get the customs regulations requirements for these shipments.
00:04:36.800 --> 00:04:39.279
But partner government agencies, it's completely different.
00:04:39.439 --> 00:04:42.720
There's even more information that needs to be provided.
00:04:43.519 --> 00:04:49.759
I'm trying to under help me understand this a little bit because I I think we use PGA here in the US for partner government agency.
00:04:49.839 --> 00:04:57.439
I think it other countries might be Canada's as participant government agencies, or they use another acronym called OGA, which is other government agencies.
00:04:57.759 --> 00:04:59.519
Um I don't know how many countries use these.
00:04:59.600 --> 00:05:01.519
I don't, I'm not the expert on this at all.
00:05:01.680 --> 00:05:03.759
But I'm trying to understand like what's the point?
00:05:03.920 --> 00:05:05.040
Like, what's their function?
00:05:05.199 --> 00:05:08.480
Why can't it all just be customs and customs do everything?
00:05:08.800 --> 00:05:13.120
Yeah, because these government agencies, they each have their own realm that they're over.
00:05:13.279 --> 00:05:16.000
For instance, FDA, uh the Food and Drug Administration.
00:05:16.160 --> 00:05:24.000
A lot of people think they only cover food and drug, but they cover cosmetics, they cover radiation-admitting devices, stuff like that.
00:05:24.160 --> 00:05:32.639
Um, and why customs can't just handle it is because these government agencies were built to regulate this stuff to make it so it's safe for Americans.
00:05:32.800 --> 00:05:36.480
So FDA handles that stuff for food and drug, cosmetics, et cetera.
00:05:36.720 --> 00:05:46.560
CPSC does it for um consumer, it's the Consumer Safety Product Commission, and they handle it for like kids' toys, cribs, et cetera, stuff like that.
00:05:46.959 --> 00:05:47.040
Okay.
00:05:47.680 --> 00:05:54.879
So the the other government agency, you've got you've got different agencies focus on different types of things.
00:05:55.199 --> 00:05:57.279
And then where does customs come in?
00:05:57.600 --> 00:06:00.000
So customs is like a partnership with them.
00:06:00.160 --> 00:06:04.480
Customs, they hold the stuff that the government agencies ask them to hold.
00:06:04.560 --> 00:06:07.839
Uh, they they work in tandem, basically, together.
00:06:08.000 --> 00:06:15.040
Um, but uh the customs relies on the other government agencies to tell them, hey, what should we hold?
00:06:15.120 --> 00:06:17.519
What sh what isn't safe to come into the United States?
00:06:17.839 --> 00:06:24.959
So each of these government agencies are writing the rules that they care about, and customs is helping to enforce that.
00:06:25.279 --> 00:06:25.519
Correct.
00:06:25.680 --> 00:06:26.000
Correct.
00:06:26.160 --> 00:06:27.519
And that's where the partnership comes in.
00:06:27.680 --> 00:06:33.759
And so customs can't just unilaterally just make a bunch of decisions and say, ah, this government agency doesn't need to worry about this, doesn't need to worry.
00:06:34.000 --> 00:06:40.959
They're just there, they're basically taking the marching orders from the government agencies about what types of shipments to hold and how to operate.
00:06:41.040 --> 00:06:51.040
And they can work together and have you know collaborate on things, but CVP's really not the one in charge on on the other government agency requirements, correct?
00:06:51.199 --> 00:06:51.360
Okay.
00:06:51.759 --> 00:06:53.519
How many government agencies are there?
00:06:53.759 --> 00:06:55.199
There's about 50.
00:06:55.839 --> 00:06:56.480
50?
00:06:56.639 --> 00:06:57.279
Yeah.
00:06:57.519 --> 00:06:58.319
Oh, wow.
00:06:58.560 --> 00:07:00.319
Okay, what are the top five?
00:07:00.720 --> 00:07:00.959
All right.
00:07:01.360 --> 00:07:02.560
Let's talk about all 50 today.
00:07:02.800 --> 00:07:02.879
Right.
00:07:03.120 --> 00:07:03.759
Starting the top.
00:07:04.079 --> 00:07:05.600
What are the what are some of the top ones though?
00:07:05.839 --> 00:07:13.439
So, first off, I think it's important to to establish who is this going to impact the most on October October 22nd.
00:07:14.000 --> 00:07:29.120
It's going to be the shippers that have no idea what we're talking about right now, and they're expected to provide this data now somehow to either the postal provider they're shipping with.
00:07:29.600 --> 00:07:33.439
Or hey, and this could be talking also too if you're not shipping postal, right?
00:07:33.519 --> 00:07:41.360
You still you need to give it to the shipper so they have enough data to then clear the shipment into the United States, right?
00:07:41.439 --> 00:07:42.560
Without issue.
00:07:42.879 --> 00:07:49.759
So um to kind of set their expectations, and we've seen this in the non-mail environment.
00:07:49.920 --> 00:07:56.079
Aaron, what happens in the non-mail environment when a shipment doesn't have enough information?
00:07:56.399 --> 00:07:59.839
Like the from this partner, go, okay, let's what's it, what's an example of a good?
00:07:59.920 --> 00:08:07.839
Let's say it's uh, I don't know, a nutraceutical or something, and it's and the broker that's importing this, it does just doesn't have enough information.
00:08:08.160 --> 00:08:09.279
What actually happens?
00:08:09.519 --> 00:08:12.639
Yeah, and we're partners a lot of commercial carriers.
00:08:12.879 --> 00:08:23.120
And when the de minimis went away last year, and now all of a sudden government other government agency information was required, um shipments get held if they don't have it.
00:08:23.279 --> 00:08:28.959
And then they're out there making phone calls, sending emails, they're they're trying to find the information.
00:08:29.040 --> 00:08:32.559
They're typically going back to the shipper to get that information.
00:08:32.720 --> 00:08:34.240
And I think that's another aspect of this.
00:08:34.320 --> 00:08:41.840
We talked about how they might say what shipments to hold, but they also have requirements on information they need, right?
00:08:42.000 --> 00:08:44.159
So some shipments can just come in.
00:08:44.240 --> 00:08:48.159
Hey, you you fill out a commercial invoice, you've got to basically send it through.
00:08:48.480 --> 00:08:49.120
It goes through fine.
00:08:49.840 --> 00:08:55.039
That's probably generally that's a lot of shipments that that can come through depending on the type of goods.
00:08:55.200 --> 00:09:01.679
And then there's others that have certain requirements, but those requirements are all the same for every government agency, right?
00:09:01.840 --> 00:09:02.799
And all across the world.
00:09:03.440 --> 00:09:18.000
It's a wide range, a huge range, depending on if it's NITS and you need like make and model of uh car information, or if you need sometimes with CPSC, you need to put to say, hey, these kids' pajamas, are they fire retardant?
00:09:18.080 --> 00:09:20.240
And do you have a certification stating that they are?
00:09:20.720 --> 00:09:32.159
But but I'm sure all 50 government agencies get together in a room and talk to each other to make it really easy on the brokers and the shippers to be able to supply a standardized set of information, correct?
00:09:32.399 --> 00:09:33.200
I wish they did.
00:09:33.279 --> 00:09:35.679
I really, really wish they did, but they do not.
00:09:36.159 --> 00:09:36.879
All right then.
00:09:36.960 --> 00:09:39.759
What because so give me some examples of government.
00:09:40.240 --> 00:09:40.960
We talked about FDA.
00:09:41.279 --> 00:09:42.159
That's probably the biggest one.
00:09:43.519 --> 00:09:44.639
What's an FDA?
00:09:44.960 --> 00:09:45.919
The Food and Drug Administration.
00:09:46.399 --> 00:09:47.039
Food and Drug Administration.
00:09:47.759 --> 00:09:48.720
Really sorry, he doesn't like African.
00:09:49.039 --> 00:09:52.399
We're talking to I'm I'm in I'm a retailer in Canada.
00:09:52.559 --> 00:09:54.879
I'm a r I'm a retailer in Japan.
00:09:55.039 --> 00:09:57.200
I have no idea what FDA is.
00:09:57.519 --> 00:09:58.320
All right, okay.
00:09:58.799 --> 00:10:02.320
The team, the team knows when I hear an acronym, I get lit up a little bit.
00:10:02.399 --> 00:10:04.639
Okay, so the food and the food and drug administration.
00:10:04.799 --> 00:10:04.960
Yes.
00:10:05.519 --> 00:10:06.720
All right, there's there's that one.
00:10:06.960 --> 00:10:12.559
CPSC, Consumer Safety Product Commission, that does, you know, kids' toys, cribs.
00:10:12.639 --> 00:10:15.919
It even does some adult products as well, like uh cleaning supplies, stuff like that.
00:10:16.240 --> 00:10:24.320
Those are probably, from what I understand, those are really, especially when it comes to can consumer goods that are typically the low-value goods, those are the two biggest ones.
00:10:24.639 --> 00:10:25.759
Those are probably the biggest ones.
00:10:26.080 --> 00:10:29.039
Can I throw in a third that I think is a big one, especially in male?
00:10:29.440 --> 00:10:30.799
The pharmaceuticals, right?
00:10:30.879 --> 00:10:31.840
That way, that's NDA.
00:10:32.080 --> 00:10:32.399
That's FDA.
00:10:32.480 --> 00:10:32.799
That's FDA.
00:10:33.600 --> 00:10:34.480
Sub bullet, sub bullet.
00:10:34.639 --> 00:10:35.039
All right, yeah.
00:10:35.200 --> 00:10:37.919
Yeah, but uh, I mean, you even have fish and wildlife.
00:10:38.159 --> 00:10:41.440
So that one comes up, and a lot of people don't think it does for them.
00:10:41.519 --> 00:10:47.600
But for instance, if you're uh importing a say a wallet that has leather, but if it's cow leather, that's okay.
00:10:47.759 --> 00:10:50.159
If it's a domesticated animal, that's that's okay.
00:10:50.399 --> 00:10:54.159
But what if you have a crocodile uh skin leather?
00:10:54.240 --> 00:10:59.200
Uh, then it is a requirement uh with fish and wildlife to provide information on it.
00:10:59.519 --> 00:10:59.840
Okay.
00:11:00.080 --> 00:11:00.480
All right.
00:11:00.639 --> 00:11:08.799
So the all the oh man, all those Australian retailers selling the crocodile leather wallets.
00:11:10.879 --> 00:11:10.960
Okay.
00:11:11.279 --> 00:11:14.399
Well, I want to I want to actually I want to touch on this a little bit more.
00:11:14.639 --> 00:11:16.639
You've dealt with a lot of different PGAs in your career.
00:11:16.960 --> 00:11:17.600
A lot.
00:11:17.919 --> 00:11:18.399
Sorry.
00:11:18.720 --> 00:11:20.320
Partner government agencies in your career.
00:11:20.639 --> 00:11:22.799
Oh, yeah, we're gonna try to use nose at this point.
00:11:23.039 --> 00:11:23.440
You're fine.
00:11:23.519 --> 00:11:23.840
You're fine.
00:11:24.000 --> 00:11:24.399
All right.
00:11:24.639 --> 00:11:28.080
Um what are some of the weirdest things you've dealt with?
00:11:28.240 --> 00:11:39.600
Like what are some we are we've only talked about three of the 50, but like there's a lot of different agencies worried about I'm I can't even think of 50 different things that they would be out there.
00:11:40.080 --> 00:11:43.840
I mean, there's a lot, I mean uh TTVs, the tobacco and alcohol.
00:11:44.000 --> 00:11:49.919
I mean, some of the weird things though, like um I had an importer import hamster ovaries once for scientific purposes.
00:11:50.080 --> 00:11:51.120
Um and I mean that can be.
00:11:51.440 --> 00:11:52.399
There's an agency for that.
00:11:52.720 --> 00:11:57.120
Well, that's the fish and wildlife there, but you know, but I guess that's domesticated animals.
00:11:57.200 --> 00:11:58.799
But yeah, no, it comes into play there.
00:11:58.960 --> 00:12:01.279
I mean, there's lots of random stuff.
00:12:01.440 --> 00:12:04.720
Um let's see, what else is out there?
00:12:04.879 --> 00:12:06.159
Well, EPA chemicals.
00:12:06.240 --> 00:12:08.080
So this one, a lot of people don't think.
00:12:08.320 --> 00:12:10.639
EPA is the environmental protection agency.
00:12:10.799 --> 00:12:22.000
If you're importing a ballpoint pen, you actually have to certify that the chemical, the ink inside, um, is uh safe basically per Tosca regulations, the EPA.
00:12:22.240 --> 00:12:25.120
And because that ink can get on your skin.
00:12:25.279 --> 00:12:28.240
And so a lot of people don't think a ballpoint pen is regulated.
00:12:28.639 --> 00:12:28.960
Okay.
00:12:29.279 --> 00:12:29.440
Okay.
00:12:30.240 --> 00:12:32.399
Well, how do you how do you do that?
00:12:32.559 --> 00:12:46.399
What's the process for giving that information, whether it be the the the wallet or the ballpoint pen, or if it's pharmaceuticals or uh children's toys or whatever it is, like each agency has something they require.
00:12:46.799 --> 00:12:52.240
And how do you what's what's the actual process in submitting and giving that information so they're happy?
00:12:52.559 --> 00:13:06.159
So if you're the one, if you're the one shipping this, you need to have the information, for instance, um if it's a food item, you need to sometimes have the um FDA registrated a rate registration number for that manufacturer who manufactured that food.
00:13:06.399 --> 00:13:08.480
And that is not something that's public knowledge.
00:13:08.559 --> 00:13:13.519
Like medical devices, that manufacture information is actually public knowledge, but not for food.
00:13:13.759 --> 00:13:19.600
And so that stuff you kind of have to be able to find out that information before you ship it.
00:13:20.240 --> 00:13:22.960
Okay, so you find out the information before you ship it.
00:13:23.039 --> 00:13:23.919
How is it supplied?
00:13:24.080 --> 00:13:24.320
Yeah.
00:13:24.480 --> 00:13:27.919
And what like mechanism, because that needs to get to the broker, right?
00:13:28.159 --> 00:13:37.200
Now, when you're not in the I actually think this is really important, when you're not in the e-commerce environment, who's interacting with you as a broker?
00:13:37.279 --> 00:13:38.720
Because it's the world you lived in before.
00:13:38.960 --> 00:13:40.000
Who's your customer?
00:13:40.320 --> 00:13:40.960
The shipper.
00:13:41.120 --> 00:13:42.399
And the the shipper, right?
00:13:42.480 --> 00:13:46.320
They're the ones that are they know all these things, right?
00:13:46.480 --> 00:13:48.960
But they're the they're the ones that are actually shipping it.
00:13:49.039 --> 00:13:52.399
You're not interacting with an intermediary between you and the shipper.
00:13:52.639 --> 00:13:55.600
You have contact with the shipper and you know what they're importing, right?
00:13:56.159 --> 00:14:09.679
I I think that this is this is sometimes the the the the weird setup in in the e-commerce environment is there becomes a disconnect with the shipper and the broker, and that's the shipping carrier, right?
00:14:10.240 --> 00:14:12.879
And which has historically been fine.
00:14:13.120 --> 00:14:13.440
Uh-huh.
00:14:13.600 --> 00:14:16.159
Historically that's been well, has uh okay, two or more.
00:14:17.600 --> 00:14:22.960
Okay, because because there wasn't all these requ you know, there wasn't much being asked of of low value shipments coming into the U.
00:14:23.279 --> 00:14:23.759
You didn't need much.
00:14:24.159 --> 00:14:36.720
Yeah, but okay, but let's let's you just brought up though the fact that fine based on the current baseline, but even in the current baseline, in the non-mail environment, they are holding packages all the time.
00:14:37.039 --> 00:14:41.200
When I say previously, when we had De Minimus.
00:14:41.360 --> 00:14:41.679
Right, right.
00:14:41.759 --> 00:14:41.919
Yeah.
00:14:42.080 --> 00:14:43.679
Yes, when you had I see what you're saying.
00:14:43.759 --> 00:14:45.440
Yeah, before De Minimis, right?
00:14:45.919 --> 00:14:49.919
This is an absolute nightmare today in the non-mail environment.
00:14:50.080 --> 00:14:51.679
Just to be clear, right?
00:14:51.919 --> 00:15:07.679
So if you've been shipping mail and you've kind of been having a pass on some of these partner government agencies in terms of them just coming in, if you had been sending this within the commercial lane, you would have had these problems.
00:15:08.000 --> 00:15:20.240
And if you weren't, then either it was easily just derived right from what you said, right, on the commercial invoice, or honestly, the broker isn't being super honest and they might be inferring things themselves, right?
00:15:20.480 --> 00:15:30.320
But if you ship with like an express carrier who has their crap buttoned up, a UPS, a FedEx, or a DHL, if they don't know that thing's getting held.
00:15:30.960 --> 00:15:33.440
It's getting caged, and they're reaching out.
00:15:33.919 --> 00:15:38.080
And this is this is really a big problem that's trying to get solved right now.
00:15:38.320 --> 00:15:42.559
Um so I I do want to talk about now that data, right?
00:15:42.639 --> 00:15:50.000
So we talked how is it how is it it can be on the commercial invoice, it can be supplied directly to the broker when you're outside the mail, when you're outside the mail environment.
00:15:50.480 --> 00:15:55.519
Um this is a lot of like you're saying a lot of things.
00:15:55.600 --> 00:16:04.240
I'm listening to this, I'm a shipper, I'm like, how do I like how do we make how how can their life be made as easy as possible?
00:16:04.480 --> 00:16:07.679
And so something that can be done, right?
00:16:07.759 --> 00:16:18.320
Whether it's their whoever they're shipping with or they're, you know, let's say they're shipping with a a um a pulsal provider, maybe that pulse provider's asking them questions to kind of help them out.
00:16:18.720 --> 00:16:26.720
But as a broker, how much can you actually infer from what's received?
00:16:26.960 --> 00:16:32.799
Do you I mean like like how often are you able to be like, okay, yes, this is kind of obvious?
00:16:32.960 --> 00:16:35.519
And then other times, like, I have a I have more questions.
00:16:36.159 --> 00:16:42.879
So you can infer some from like the description and what it is, maybe being like, okay, this would be subject to FDA.
00:16:42.960 --> 00:16:46.080
I mean, if we have the HTS, then it flags for those type of things.
00:16:46.240 --> 00:16:49.279
Um, but within, for instance, say it flagged for FDA.
00:16:49.440 --> 00:16:58.559
We can infer completely because some items are classified on the same HTS that one could be a cosmetic, one could be um uh a food.
00:16:58.720 --> 00:17:02.000
I mean, there could be all sorts of different um things within that.
00:17:02.240 --> 00:17:02.799
Yeah, okay.
00:17:02.960 --> 00:17:19.759
So, Aaron, outside the United States, when it's an individual shipper right now, we've actually had a kind of a chance to to beta some of this, where someone downloads our mobile app, let's say in Japan, and they take a picture of the good, it figures out the HTS, right?
00:17:19.839 --> 00:17:22.240
They see kind of like how it's being classified.
00:17:22.640 --> 00:17:29.599
And what happens when it is going to be some type of partner government agency here?
00:17:29.680 --> 00:17:31.519
What what's the experience for the shipper?
00:17:32.079 --> 00:17:43.839
And give some numbers around um uh how smooth their experience is, um, how often like it can just be pretty much just one and done almost, and when it can't.
00:17:44.160 --> 00:17:56.880
Yeah, so um A, since you're inner the ship, I mean, let's be honest, a foreign shipper anywhere in the world is not going to be the foremost expert on US partner government agencies, right?
00:17:57.119 --> 00:18:02.400
So you've got to make sure you you you give them the information in a way that's understandable for them to easily uh ask.
00:18:02.480 --> 00:18:10.880
Now, you take that to a retail shipper and some you know low-volume shipper, just occasionally you know drop something off to the post office.
00:18:10.960 --> 00:18:13.119
You need to make it easy for them to go through the process.
00:18:13.279 --> 00:18:21.759
So you ask them some questions in really plain English or Spanish or French or Japanese, whatever their language is.
00:18:21.839 --> 00:18:22.640
So that's key.
00:18:22.720 --> 00:18:23.680
That's number one.
00:18:23.839 --> 00:18:26.400
And then um make it so it's easier to understand.
00:18:26.559 --> 00:18:32.160
And then also we can help to infer and say, hey, here's what we think, this is what we see based on um our expertise.
00:18:32.319 --> 00:18:33.359
Does this look right?
00:18:33.519 --> 00:18:37.759
And they can say, Yeah, that actually does look right, or no, let me change a few things.
00:18:38.000 --> 00:18:40.400
And we're right about 85% of the time.
00:18:40.480 --> 00:18:42.000
And they say, Yeah, that actually looks right.
00:18:42.079 --> 00:18:56.640
And so it makes it within seconds, they can they can answer these questions, give the information, and this has been some awesome data leading up to because you know, even though it's still going on a spreadsheet right now, this data, so but we're already doing what we should be as a broker, right?
00:18:56.720 --> 00:18:58.799
Which is asking these questions to the shipper.
00:18:59.519 --> 00:19:02.319
What's what's incredible about this data, it's two things.
00:19:02.400 --> 00:19:10.240
One, 85% of the time, we are able to present to them, like, here's based on you took a photo, I can get a lot, right?
00:19:10.319 --> 00:19:16.559
Like we can we can start inferring a lot of information about the good, and they can attest and say, Yep, that's accurate.
00:19:16.799 --> 00:19:19.519
So I think that you know that's an that's an incredible number.
00:19:19.839 --> 00:19:27.599
The invert is also crazy, which is, and I think it's 80, 86, 14 is kind of the numbers, but you're you're closer.
00:19:27.920 --> 00:19:30.079
On the 14%, give or take.
00:19:30.480 --> 00:19:30.960
Give or take.
00:19:31.039 --> 00:19:36.160
You're rounding on that other 14%, it means we didn't infer correctly.
00:19:36.319 --> 00:19:38.480
We have a team of data scientists that do this.
00:19:38.960 --> 00:19:58.160
And the reason that's important is if a broker says they can do it 100% of the time, either they have a team of data scientists better than us that are, you know, and also probably better than something like uh I don't know, anything else in the world, um, or they're not doing it properly.
00:19:58.319 --> 00:20:08.319
Because or Angela, do you think a broker can infer 100% of the time what's uh what's actually that is based on either a picture or the description or anything like that?
00:20:08.640 --> 00:20:17.759
No, they can't, and especially um, even if it's inferred that it's an FDA, FDA requires the manufacturer information and they cannot just provide anything.
00:20:17.839 --> 00:20:23.279
They can be like, oh yeah, the manufacturer is my sister, put her name and address.
00:20:23.599 --> 00:20:35.519
Because if they are putting that information and it's incorrect, say the broker inferred that and it's incorrect, FDA flags it, exams it, and says, Nope, this is wrong.
00:20:35.680 --> 00:20:37.279
Give me the required information.
00:20:37.920 --> 00:20:38.559
Yep.
00:20:38.960 --> 00:20:43.920
So, okay, so we you you you can't always just infer, so you got to get that data.
00:20:44.079 --> 00:20:53.200
And now it's all about okay, now how do you build this experience out for um uh for these these retailers?
00:20:53.359 --> 00:20:56.240
So now now we're kind of in like how do I comply, right?
00:20:56.319 --> 00:21:13.039
We've talked about what they are, um uh the difficulty, and you know, really just kind of actually before I get how I comply, because I've missed a bullet, we need to talk about pharmaceuticals, and then let's get to the compliance part.
00:21:13.359 --> 00:21:19.599
And the reason I uh Aaron, why is why do you think pharmaceuticals is like a carve out here discussion?
00:21:20.559 --> 00:21:27.119
Well, pharmaceuticals are very, very tightly controlled when it comes to the US.
00:21:27.279 --> 00:21:30.640
I mean, look, how much how much has fentanyl been in the headlines?
00:21:31.039 --> 00:21:31.200
Right?
00:21:31.359 --> 00:21:35.920
So, but in general, all of this stuff is very, very tightly regulated.
00:21:36.799 --> 00:21:42.960
And so if you if you look historically, UPS has been fined$40 million.
00:21:44.480 --> 00:21:47.440
Uh FedEx had a whole lawsuit they went through.
00:21:47.519 --> 00:21:52.000
They ended up winning, but it was like a civil lawsuit against them in into the billions.
00:21:52.079 --> 00:21:53.920
Um, that luckily they won.
00:21:54.160 --> 00:21:58.960
Um, that says, Hey, you as the broker clearing this, you need to do everything right.
00:21:59.279 --> 00:22:10.240
Um And it's interesting how much pharmaceuticals go in direct to consumer through the mail, but aren't going through the commercial channel.
00:22:10.400 --> 00:22:11.279
Why is that?
00:22:11.599 --> 00:22:13.680
Oh, it's because they can.
00:22:14.000 --> 00:22:14.720
Because they can.
00:22:14.880 --> 00:22:19.920
Because they can because it's coming in outside the view of these other government agencies.
00:22:20.240 --> 00:22:24.640
I was going to say it's the path of least resistance, but it's more like the path of no resistance.
00:22:26.079 --> 00:22:30.160
And so it's this this is this is about to get closed, right?
00:22:30.240 --> 00:22:34.000
We were talking to a postal operator the other day, and they're like, I get it.
00:22:35.200 --> 00:22:42.559
And we're going to jump on a lot of calls with their shippers, but I get it that there's a lot of things that are shipping that is non-compliant.
00:22:42.799 --> 00:22:55.119
So I think one, if you sh sell pharmaceuticals online and a lot of things with FDA, but there is a chance you won't be able to do it anymore.
00:22:55.599 --> 00:22:56.799
There is there is a chance, right?
00:22:56.880 --> 00:22:59.839
That you are actually shipping something that cannot come in, period.
00:23:00.559 --> 00:23:02.720
And then there's a chance you can.
00:23:02.799 --> 00:23:05.759
And in the in the world of pharmaceuticals, let's say I can.
00:23:06.160 --> 00:23:08.799
What are what are what now is required?
00:23:08.960 --> 00:23:16.720
What are some examples of um whether it's prescription drugs, non-prescription, uh, I don't know, whatever else is on your mind, Angela.
00:23:16.799 --> 00:23:25.599
What what are so how do I now actually ship these types of goods into the United States?
00:23:25.920 --> 00:23:30.160
And we already, you know, we'll talk about how to get the data, but I'm more interested in like what data is needed.
00:23:30.240 --> 00:23:31.359
What do they need to do?
00:23:31.839 --> 00:23:32.160
Yeah.
00:23:32.319 --> 00:23:43.039
So with pharmaceuticals in general, especially prescription, it gets really complicated because for there is a personal use exemption with FDA.
00:23:43.279 --> 00:23:56.640
So they still need to supply, hey, a letter from the consumer here in the US saying it is for personal use, and here's my doctor's information that um wrote this prescription for me.
00:23:56.960 --> 00:24:00.400
And then FDA can even request that prescription.
00:24:00.640 --> 00:24:02.880
And that is not something a broker can ever infer.
00:24:02.960 --> 00:24:04.640
We we can't infer a prescription.
00:24:05.119 --> 00:24:07.279
And so that needs to be provided.
00:24:07.440 --> 00:24:20.319
Also, right now, as the regulations stand, if that drug that's a prescription drug, is already sold in the United States, then it cannot come in even under the personal use exemption.
00:24:22.000 --> 00:24:22.319
Okay.
00:24:22.559 --> 00:24:26.400
So it has to be a drug that is currently not for sale.
00:24:26.640 --> 00:24:27.759
That's the starting point.
00:24:28.079 --> 00:24:30.559
If it's not available inside the United States, okay.
00:24:31.200 --> 00:24:33.440
But you have a prescription.
00:24:33.519 --> 00:24:38.480
So now we're talking from the standpoint of I'm inside the United States, but I have a prescription.
00:24:38.640 --> 00:24:46.160
What happens though if like it is available and I I think I probably know the answer actually based on what you said, but it is in the United States, it is available.
00:24:46.240 --> 00:24:52.640
I'm traveling here and my doctor's overseas, like what what and I need my prescription.
00:24:52.960 --> 00:24:57.680
So there is a foreign visitor um exemption where if you are not based in the I didn't know the answer.
00:24:57.759 --> 00:24:58.000
This is good.
00:24:58.079 --> 00:24:58.160
Okay.
00:24:58.640 --> 00:24:59.039
It's okay.
00:24:59.200 --> 00:25:19.519
If you are not based in the United States um and you come, say, for a trip for two weeks and you forgot your medication, well, if you're able to then provide that information, you can get the prescription that is already sold here in the US, um, as long as you have that prescription from the foreign entity, the foreign doctor, and you're able to uh ship that into the United States if you're a visitor.
00:25:19.920 --> 00:25:26.240
So lots of paths of like questions and answers that leads to yes or no's, right?
00:25:26.799 --> 00:25:27.680
Or documentation.
00:25:27.759 --> 00:25:27.920
Yeah.
00:25:28.160 --> 00:25:28.319
Right.
00:25:28.480 --> 00:25:34.880
Yes, yes or no's on the documentation, yes or no's on the import, and yes or no on okay, what kind of documentation do I need?
00:25:35.119 --> 00:25:38.559
Um and this is a lot of things that we're we're doing right now in the mobile app, right?
00:25:38.640 --> 00:25:42.160
At least from the the the individual shipper's perspective overseas.
00:25:42.240 --> 00:25:47.200
So if your grandma's shipping you something into the US, we'll make your life as easy as possible.
00:25:47.440 --> 00:25:49.680
Um that's fascinating.
00:25:49.920 --> 00:26:07.759
Yeah, now I one other interesting thing about this is um, you know, you would sometimes we we just think, oh, well, the FDA clearly has been thinking about this on all these low-value mail shipments and everything, you know, in this whole new process.
00:26:07.839 --> 00:26:12.319
And they're they're gonna make sure they have the most practical, reasonable requests, right?
00:26:12.960 --> 00:26:19.440
Well, I wish that was the case, but I'm not sure they fully grasp the concept of what is in the mail environment.
00:26:19.759 --> 00:26:27.359
And I think that's key is they're learning too, because what they have is all the regulations they built for a different type of environment.
00:26:27.519 --> 00:26:34.640
You know, this is this is goods coming into pharmacies and you know, higher value shipments that are cleared with a broker.
00:26:34.799 --> 00:26:37.279
Like there, there's a very controlled process with that.
00:26:37.519 --> 00:26:44.960
But this direct-to-consumer low-value shipment mail environment um is something that they they there's a lot of unknowns for them as well.
00:26:45.039 --> 00:26:48.000
And this isn't just the FDA, this is this is all the government agencies.
00:26:48.400 --> 00:26:50.160
Yeah, none of them had the data before.
00:26:50.319 --> 00:26:55.440
None of them had insight into what was coming because nobody ever had to submit something to them.
00:26:55.759 --> 00:26:57.039
Let's talk about that.
00:26:57.359 --> 00:27:02.799
A year ago, when there was a de minimis, what was the clearance process like on a low value shipment?
00:27:03.119 --> 00:27:04.559
It was completely easy.
00:27:04.640 --> 00:27:11.599
You didn't really have to, I mean, you had to pay the duties and taxes if there happened to be some, but um you really it would just go through.
00:27:11.839 --> 00:27:14.640
There was nothing to partner government agencies, there was nothing provided.
00:27:15.119 --> 00:27:16.160
This is type 86, right?
00:27:16.319 --> 00:27:17.039
Yeah, type 86.
00:27:17.279 --> 00:27:22.160
So these government agencies have been completely blind to low value shipments effectively for years.
00:27:22.400 --> 00:27:22.559
Right.
00:27:22.799 --> 00:27:27.839
Then they started getting some information a year ago on the commercial side, and now mail is a whole new thing.
00:27:28.480 --> 00:27:30.079
Commercial ended up with a huge problem.
00:27:30.160 --> 00:27:30.480
Uh-huh.
00:27:30.720 --> 00:27:38.640
And what's crazy is okay, commercial has a huge problem, but Aaron, and that's that's with these partner government agency shipments.
00:27:38.720 --> 00:27:41.759
They have they do it, they have a big problem because they're trying to figure this out.
00:27:42.160 --> 00:27:44.960
But where's the majority of this volume going through?
00:27:45.200 --> 00:27:46.000
Well, the mail.
00:27:46.160 --> 00:27:50.000
So how big's the problem going to be in mail come October 22nd?
00:27:51.119 --> 00:27:51.519
Huge.
00:27:51.839 --> 00:27:52.720
It's gonna be big.
00:27:53.279 --> 00:28:06.799
And I think uh we'll it'll be we don't know how big, but because I think customs is trying not to know you don't want to like have a standstill on everything, but it's gonna be an absolute cluster.
00:28:06.880 --> 00:28:08.480
It's gonna be an absolute mess.
00:28:09.759 --> 00:28:12.720
And so there's a lot of like everybody's trying to figure this out.
00:28:12.799 --> 00:28:14.160
Like, is there other easy buttons?
00:28:14.319 --> 00:28:16.079
Like, like I I don't I don't blame.
00:28:16.240 --> 00:28:19.440
I've I'm a if I'm a shipper, I'm like, what's my easy button?
00:28:19.599 --> 00:28:19.759
Right?
00:28:20.240 --> 00:28:25.039
If I'm a post postal operator, I'm like, what what easy buttons do we got here?
00:28:25.359 --> 00:28:31.839
With CPSE, right, which is the the consumer consumer product safety conditions.
00:28:32.319 --> 00:28:34.960
I had to say the acronym because I don't even know what the other thing means.
00:28:35.279 --> 00:28:39.839
All right, so with the with okay, I'm just gonna use CPSE.
00:28:39.920 --> 00:28:47.839
So with CPSE, there's um I Okay.
00:28:48.640 --> 00:29:01.039
There's like a regist okay, a certificate and identifiers like what what what's required on CPSE and then can it be reused on every single shipment, like that information, or like how does it how does it work?
00:29:01.519 --> 00:29:03.039
So it there's two different ways.
00:29:03.200 --> 00:29:12.160
You could set up a registry um with that uh to be able to supply the information ahead of time, and then yes, provide these three identifiers to your broker to clear it.
00:29:12.240 --> 00:29:15.839
And if you're shipping that same item over and over, you can do some of that.
00:29:16.240 --> 00:29:22.720
But um it really matters if you have the information first and submit for that certificate to prove that it is safe.
00:29:23.039 --> 00:29:25.920
And that certificate comes from CPSC, right?
00:29:26.079 --> 00:29:34.559
Yes, yeah, you you submit you're submitting like testing information, all that stuff, and getting in a reference number for your product that then you can use on all your shipments of that product.
00:29:34.640 --> 00:29:35.039
Is that the same?
00:29:35.200 --> 00:29:36.480
Of that specific product, yep.
00:29:36.799 --> 00:29:37.519
Okay, that makes sense.
00:29:37.759 --> 00:29:55.680
And so I think generally that as much as we want easy buttons, we the best thing we can do is provide easy processes, as easy as possible, versus okay, we can just infer be or like, yeah, you there they you are gonna have to provide information.
00:29:56.240 --> 00:29:56.720
100%.
00:29:57.200 --> 00:29:58.720
Yeah, but you can that's unique.
00:29:58.960 --> 00:30:04.240
Why can't we oftentimes make crap up and then just to get it through as long as nobody else questions?
00:30:04.720 --> 00:30:07.839
Hey, hey Aaron, you actually you can want me to give you some examples?
00:30:08.079 --> 00:30:08.240
Yeah.
00:30:08.480 --> 00:30:09.119
So all right, yeah.
00:30:09.200 --> 00:30:15.759
So the I think that the you know, I you know I think there's that broker got shut down.
00:30:15.920 --> 00:30:16.319
Hold on.
00:30:16.480 --> 00:30:18.079
There's another one that I think is getting fine.
00:30:18.160 --> 00:30:25.359
Aaron, you were just at the uh how well is this going for people that are it's not going well, and this is actually that type of mentality.
00:30:26.000 --> 00:30:32.160
And honestly, there's a lot that have been getting away with it, but it's changing.
00:30:32.240 --> 00:30:46.799
And in fact, that that's where the theme was as far as CVP is concerned, is like, hey, if we come asking, or if another government agency comes asking for more information, or to say, How did you get this information?
00:30:47.279 --> 00:30:50.960
They're really fed up with the answer of like I I I I don't know.
00:30:51.200 --> 00:30:52.880
Yeah, um, I just made it up.
00:30:52.960 --> 00:30:53.599
I I don't know.
00:30:53.759 --> 00:31:02.000
And instead of saying, Oh, we got a from this shipper and this is their documentation, here's all this extra information that that backs up our claim.
00:31:02.160 --> 00:31:03.440
That goes over well, right?
00:31:03.599 --> 00:31:04.960
And that's the expectation.
00:31:05.119 --> 00:31:12.799
But if none of that's there, if it's hollow behind that that initial entry, that's where there's a big problem, and that's where a lot of people get are getting shut down.
00:31:13.039 --> 00:31:18.160
If you're if you're a US broker, my message would be get ready to get graded on a curve, right?
00:31:18.319 --> 00:31:22.319
Hey, this is like uh um natural selection here.
00:31:22.480 --> 00:31:26.319
If you we're all running, Aaron, I'm out running you, and the bear's getting you, right?
00:31:26.400 --> 00:31:33.920
So it's like you just need to be do as good as you be, you bet not as not just as good as you can, you need to be better than the other guy, right?
00:31:34.000 --> 00:31:35.599
Because this is going to happen.
00:31:35.759 --> 00:31:38.960
And when customs walks in and they're like, this is reasonable.
00:31:39.039 --> 00:31:39.920
What are you talking about?
00:31:40.079 --> 00:31:42.079
I have this data from somebody else.
00:31:42.319 --> 00:31:43.680
What are you going to say?
00:31:44.079 --> 00:31:56.400
And and this is it's it's I know this is problematic, and and we're all trying to figure this out as brokers in the industry, but I can't think of any other way, better way to say it than you better be better than not just the next guy, it's a lot of the other guys, right?
00:31:56.480 --> 00:32:01.200
Like you you be because nobody's been great until now.
00:32:01.359 --> 00:32:02.880
I'm sorry, no one's been great yet.
00:32:02.960 --> 00:32:07.359
And so you we gotta figure out what group good looks like and execute.
00:32:08.240 --> 00:32:11.200
Okay, now back to the individual shippers.
00:32:11.279 --> 00:32:14.240
I'm a business Aaron, and so these questions are for you.
00:32:14.640 --> 00:32:18.480
Uh, and we don't want to talk too much about kind of what we do, but I think this is kind of relevant.
00:32:18.559 --> 00:32:18.720
Yeah.
00:32:19.039 --> 00:32:25.519
Um, because we have tons of shippers in Canada, Japan, Australia, right?
00:32:26.079 --> 00:32:27.279
This is coming.
00:32:27.839 --> 00:32:35.119
I have a massive catalog, or I have, you know, I sell online, I'm subject to one of the partner government agencies.
00:32:35.359 --> 00:32:36.559
What's my experience like?
00:32:36.720 --> 00:32:38.400
What how do you make my life easy?
00:32:38.640 --> 00:32:40.319
Because I don't use a mobile app.
00:32:40.400 --> 00:32:41.359
I mean, we kind of talked about that.
00:32:41.440 --> 00:32:43.440
So the how on the mobile app was kind of explained.
00:32:43.519 --> 00:32:47.680
But what happens if I'm I'm I'm sending thousands and thousands of shipments a day?
00:32:47.920 --> 00:32:55.279
Yeah, so uh let's talk about the the one that's workable but not ideal, uh, which is hey, I might get an email.
00:32:55.519 --> 00:33:00.640
Uh that you know, I'll send you an email that says, Hey, I need more information on this particular product.
00:33:00.720 --> 00:33:03.519
So you can ship, and maybe that a lot of your products don't need extra information.
00:33:03.759 --> 00:33:04.480
So it's in transit.
00:33:04.799 --> 00:33:12.480
You may never hear anything, but on something that's in transit, I'm gonna get an email or gonna send you an email and a message, say, hey, we need some information here.
00:33:12.640 --> 00:33:12.960
Okay.
00:33:13.279 --> 00:33:17.759
Um the cool thing is you can supply that information and we can save it for the next time that product ships.
00:33:17.920 --> 00:33:18.480
That's great.
00:33:18.720 --> 00:33:22.960
But wouldn't you like to be ahead of this instead of getting spammed with a whole bunch of uh sure?
00:33:23.039 --> 00:33:25.200
So yeah, so how do you how do you get ahead of it?
00:33:25.359 --> 00:33:28.319
Because I think that's fine for maybe some smaller shippers, right?
00:33:28.799 --> 00:33:30.559
But I want to get ahead of it, you know.
00:33:30.640 --> 00:33:35.440
Um I sell on Shopify, I sell on eBay, um, I sell on Etsy.
00:33:36.000 --> 00:33:37.200
How do how do what do I do?
00:33:37.519 --> 00:33:42.799
This is the easiest thing for you to do, and this is honestly how it works in the commercial environment.
00:33:42.960 --> 00:33:48.400
I can I can talk about that second here, with but is just catalog everything ahead of time.
00:33:48.640 --> 00:33:54.720
Our tools go through and screen it and ask for the questions ahead of time, and then and then you're then when that product ships, you're good.
00:33:54.799 --> 00:34:09.199
And the the best part is how we build that catalog, if you're on Shopify eBay, Etsy, you know, there's there's a whole bunch of channels, you can connect your store, we can pull all of that in dynamically, screen it, ask the questions on the on the products where we need more information, and you're done.
00:34:09.360 --> 00:34:15.599
Um, if we don't have, if you have a custom thing, uh site or something we could you can upload a CSV file of your catalog.
00:34:15.840 --> 00:34:16.719
Or even time to the API.
00:34:16.800 --> 00:34:17.280
We've had shippers.
00:34:17.599 --> 00:34:20.000
We had a pharmaceutical customer customer recently, right?
00:34:20.320 --> 00:34:23.840
So okay, let me tell you how this works and how awesome it is.
00:34:24.079 --> 00:34:27.840
There was there was a recent example of, and I think it was pharmaceuticals, right?
00:34:28.000 --> 00:34:29.519
Um the one that Nick was dealing with.
00:34:29.840 --> 00:34:30.239
Yeah.
00:34:30.400 --> 00:34:39.440
Um, that there we were getting if we didn't have enough information that was coming in from the postal operator, and they were getting, I think, an extra 100% tariff.
00:34:39.519 --> 00:34:42.079
Like it was, it was pretty, pretty, pretty brutal.
00:34:42.320 --> 00:34:44.400
And so the shipper's upset, right?
00:34:44.480 --> 00:34:45.679
We don't want to classify it wrong.
00:34:45.920 --> 00:34:48.239
Like we want to do it right, but we're missing data.
00:34:48.480 --> 00:34:51.039
And so the customer's like, Do you got an API?
00:34:51.280 --> 00:34:51.840
What happened?
00:34:52.079 --> 00:34:53.039
They signed the API.
00:34:53.679 --> 00:34:54.480
How'd it work?
00:34:54.960 --> 00:34:55.840
Very well.
00:34:56.159 --> 00:34:57.199
We connected, right?
00:34:57.280 --> 00:34:59.840
So we they connected the shipment with the tracking number.
00:34:59.920 --> 00:35:10.079
So they told us, hey, the shipment, here's the shipment with the tracking number, and they gave us all the additional data on every single shipment because the data that's coming through the pulseal stream is incomplete.
00:35:10.400 --> 00:35:12.639
We completed it and it worked.
00:35:12.880 --> 00:35:14.480
Yeah, and I think that brings up a good point.
00:35:14.639 --> 00:35:18.320
There is the you gotta get this data just to be compliant and not get in trouble.
00:35:18.559 --> 00:35:19.519
Okay, that's one.
00:35:19.679 --> 00:35:24.239
But there's also a whole nother set of data that can be captured to reduce tariffs.
00:35:24.480 --> 00:35:25.360
What else reduces tariffs?
00:35:25.440 --> 00:35:25.920
Look, you know what?
00:35:26.000 --> 00:35:43.519
I know we talked about partner government agencies, but really quick, and it there's like still in aluminum the 232 tariffs, uh, you know, getting that type of that content information will uh we'll get uh FTAs, you know, if you want to free trade agreements to to give your certificate of origin and those that type of information so we can you know get duty-free treatment.
00:35:44.000 --> 00:35:55.039
All of those things are documentation requirements, data requirements that are either those are for an advantage from a cost perspective.
00:35:55.199 --> 00:36:15.440
Um, and then there's then there's the compliance side of it too, with the other government agencies, but it's all really the same problem uh of just hey, the more information, the more data you get, the more compliantly you can clear it, and the better your stuff's gonna be clearing because you're gonna set a precedent that you're a compliant shipper, um, and then you're gonna you're gonna get the best possible tariff rates out there.
00:36:15.599 --> 00:36:16.079
Yeah.
00:36:16.480 --> 00:36:17.119
This is awesome.
00:36:17.679 --> 00:36:19.519
Anything else that we that I might have missed?
00:36:19.679 --> 00:36:20.880
Any questions, Aaron?
00:36:22.000 --> 00:36:23.360
I still, okay.
00:36:24.079 --> 00:36:30.079
Craziest thing that you've seen with with PGAs or just clearance brokerage in general, just the most oddball thing.
00:36:30.159 --> 00:36:30.960
I'm putting you on the spot.
00:36:31.039 --> 00:36:33.360
We didn't we did not prep her ahead of time for this.
00:36:33.440 --> 00:36:36.159
So I'm gonna ramble for a few more seconds while she starts thinking.
00:36:36.320 --> 00:36:38.239
I just want to hear a cool story.
00:36:38.639 --> 00:36:39.599
A cool story.
00:36:39.679 --> 00:36:42.320
Well Or a crazy weird one that you wouldn't even think of.
00:36:42.559 --> 00:36:42.880
Okay.
00:36:43.360 --> 00:36:57.280
So uh I guess one thing that I could think of that I mean, I guess it doesn't have to do specifically with partner government agencies necessarily, but um, like there's random regulations that come up with uh any import into the US.
00:36:57.360 --> 00:37:01.280
And sometimes these regulations are have been old standing and they still apply.
00:37:01.440 --> 00:37:11.280
But one thing that I kind of bring up that kind of blows people's mind is did you know that if you are importing a switchblade into the country, that you actually have to be a one-armed man?
00:37:11.599 --> 00:37:16.000
Because nobody else can import a switchblade into the country unless you are a one-armed man.
00:37:16.639 --> 00:37:17.440
Hold on.
00:37:18.800 --> 00:37:22.400
How do you how do you know as a broker?
00:37:22.559 --> 00:37:24.880
How would you know that it's a one-armed picture?
00:37:25.199 --> 00:37:28.480
There's no way you would know unless I don't know, you have to ask them right?
00:37:28.719 --> 00:37:29.599
Yes, you do have to.
00:37:30.000 --> 00:37:31.440
It's not something that I can infer.
00:37:31.519 --> 00:37:32.320
Are you a one-armed?
00:37:32.480 --> 00:37:33.280
I mean, how do you infer that?
00:37:33.519 --> 00:37:40.000
So if we see a switch blade coming in that we're supposed to clear, we're going to have to ask.
00:37:40.480 --> 00:37:42.079
Outreach to the receipt to the recipient.
00:37:42.480 --> 00:37:43.679
Do you only have one arm?
00:37:44.159 --> 00:37:46.559
Did you did you tell the engineers this needs to get built in yet?
00:37:46.719 --> 00:37:51.920
Because it seems like that's or a woman, you know, I'd assume.
00:37:52.079 --> 00:37:54.400
So that's wild.
00:37:54.639 --> 00:37:55.760
I was that's a good example.
00:37:55.840 --> 00:37:57.280
But it actually kind of makes sense.
00:37:57.760 --> 00:38:02.559
If it's the story we're telling, like there's certain things that can't come in unless.
00:38:02.800 --> 00:38:03.119
Unless.
00:38:03.199 --> 00:38:03.440
Uh-huh.
00:38:03.519 --> 00:38:03.760
Right?
00:38:03.840 --> 00:38:05.920
And now you have to be able to get the unless.
00:38:06.159 --> 00:38:06.880
The unless.
00:38:07.119 --> 00:38:08.559
And that's true.
00:38:08.800 --> 00:38:09.119
That's in.
00:38:09.360 --> 00:38:13.840
Yeah, so there's a lot of no's and there's a lot of it sounds like wild exceptions.
00:38:14.000 --> 00:38:14.239
Yes.
00:38:14.480 --> 00:38:18.880
I love that we get to end the podcast with a one R man story.
00:38:19.280 --> 00:38:19.679
All right.
00:38:19.920 --> 00:38:21.599
Looking forward to uh to another one.
00:38:21.679 --> 00:38:23.440
So hopefully hopefully this was helpful.
00:38:23.599 --> 00:38:24.480
We'll do a little bit better.
00:38:24.559 --> 00:38:26.400
Feel free to ask some questions in the comments.
00:38:26.480 --> 00:38:29.760
Um, and uh we'll we'll jump in and and reply to some of those.
00:38:29.840 --> 00:38:31.039
So thanks for thanks for listening.
00:38:31.199 --> 00:38:32.000
Thanks, Angela.
00:38:32.159 --> 00:38:32.960
Thank you.
