RFID Costs Still Problematic

I was disappointed recently to read of JC Penney’s (JCP) decision to defer its plans for RFID (Radio Frequency Identification) implementation in its retail stores. Following steady success by retail giants Wal Mart, American Apparel, Marks & Spencer and others in recent years, JC Penney appeared to be adopting an RFID leadership position with reported claims last year it would be 100% RFID enabled by February 2013.

In an interview with Forbes Magazine, JCP CEO Ron Johnson (former retail executive with Apple & Target) laid out an aggressive plan to streamline the customer experience by combining RFID, high speed WiFi and mobile POS systems in order to reduce the number of cash transactions at store level.
Besides speeding up the customer checkout process, one of Mr. Johnson’s main objectives in implementing comprehensive RFID ticketing was tackling the labour-intensive retail checkout process, estimated to account for 10% of JCP’s in-store labour costs, to the tune of approximately half a billion dollars annually. Building on JCP’s past RFID experience, he saw a win-win in going for full end-to-end integration: improved customer service, increased efficiencies related to information availability, and lower overhead cost.

Those of us who embrace the concept of RFID as a supply chain enabler see past the retail advantage here and appreciate the impact on inventory management (item level identifiers, in-stock ratios, locator advantages) and vendor management (procurement, data sharing, demand management forecasting, etc.). In other words, RFID still holds tremendous potential for overall supply chain efficiencies.

While size limitations, and costs, of RFID tags were frequently cited as the main barriers for robust RFID implementation by many companies, manufactures like Hitachi and Murata have successfully designed tags small enough to be easily accommodated in product labels. And with the costs of some passive tags (non-transmitting) heading below $0.10, Mr. Johnson felt those costs had declined enough in recent years to make the benefits of RFID worthwhile.

He was also leapfrogging the problem of waiting for (additional) vendor implementation as a first step, deciding instead to implement RFID at retail and push it back through the supply chain as an incentive for suppliers to begin full-case tagging. Using his Apple experience as a blueprint, he also envisioned the eventual end of traditional cash registers by enabling customers to check out on their mobile devices.

Surprising then, when just last month JCP announced an abrupt about face, stating that the full RFID initiative would be deferred, and only implemented for selected clothing and fashion jewelry items. The reason? Cost, not tag costs, but infrastructure costs.

In essence, a department store is really a warehouse, a storage location farther along the supply chain than the traditional distribution centre. And like a warehouse, goods are sometimes misplaced, or in the case of a department store, picked up from one location by a customer and put down in another. One of the challenges facing JCP was that using an RFID reader in one department to verify inventory was only half the problem, the other half was locating the item if it wasn’t there. And to solve that problem, JCP would need a far more extensive network of RFID readers throughout their stores, along with supporting hardware and software requirements.

The additional infrastructure costs were apparently more that JCP was willing to absorb, a decision undoubtedly influenced by declining sales and a third quarter loss last year of more than $100 million.

Despite the ongoing, if incremental, success of RFID implementations, the issue of cost remains pivotal for many organizations, with initial concerns over tag costs replaced by fears over escalating infrastructure costs, and with good reason. Recent studies for data capacity related to RFID reveal that organizations may have to accommodate 10 – 100 times the amount of information that could be generated by barcode systems (Winans, 2005), and the resulting infrastructure costs can be as high as $13 – $23 million for a large manufacturer (International Journal of Management and Information Systems, 2010)

Regardless of JCP’s delayed start, Ron Johnson accomplished more in 6 months than the organization did in the previous 6 years in terms of laying out an RFID game plan. He identified a vision, showing customers, employees, and observers alike, what’s possible.

Like all of us enamored with the concept of RFID, Ron Johnson gets it, more than most. RFID is the missing link, the technology that holds the potential for truly integrating business processes, redefining the meaning of communication, and transforming the supply chain by making questions like “who, what, where and when” redundant.

Posted by: Laurie Turnbull, CITT, P.MM – Supply Chain Consultant, Cole International

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Effective December 31, 2012: Enhanced Transport Canada Air Cargo Security Requirements

Effective December 31, 2012, key air cargo security requirements take effect for domestic and international passenger flights departing CATSA (Canadian Air Transport Security Authority) – designated Canadian airports.

100% of cargo transported onboard domestic and international passenger flights departing a CATSA-designated Canadian airport must come from a Registered Shipper or be screened as per Part 2 of the Security Measures Respecting Air Cargo (SMRACs). Air carriers will no longer be able to transport cargo using (known shipper and unknown shipper protocols).

This means that 100% of cargo transported onboard a domestic or international passenger flight must come from a Registered Shipper or be actively screened using one of the four approved screening methods in the SMRAC’s.

Registered shippers may tender directly to the air carrier or through an Approved Participant such as Cole International Inc.

Cargo requiring screening by an Air Carrier may be subject to additional fees and delays. The screening fees may vary based on the airline involved.

The 100% secure non-palletized cargo requirements for transborder passenger flights are already in effect, requiring that non-palletized cargo transported onboard a transborder passenger flight be accepted from a Registered Shipper (directly or through an Approved Participant) and screened using one of the four approved screening methods.

Avoid screening fees and potential delays by ensuring that you are a Registered Shipper.

If you have any questions related to this matter, please contact your local Cole International Representative.

The Transport Canada Air Cargo Security web site is: http://www.tc.gc.ca/eng/aviationsecurity/asc-41.htm

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Effective January 1, 2013: Full Mandatory Harmonized System (HS) Codes Required at Time of Customs Release

Mandatory HS (Harmonized System), a major Government of Canada initiative, is about getting the right information at the right time to allow the CBSA to identify and mitigate potential threats to Canada while facilitating the movement of low-risk shipments across the border.

Building on the previous phases of the ACI initiative the customs tariff will be required with the electronic transmission of advance trade data from importers. Effective January 1, 2013 HS Code for all lines up to 999 lines will be required for Electronic release requests (PARS/RMD) transmitted via the Electronic Data Interchange (EDI). Electronic release requests not conforming to the above minimum number of HS Codes will be rejected with a possible AMPS penalty being issued.

Timeframe for   HS Code Requirements Number of HS Codes Required
September 1, 2011 Minimum of 10 HS Codes
February 1, 2012 Minimum of 20 HS Codes
June 1, 2012 Minimum of 30 HS Codes
January 1, 2013 HS Code for all lines up to 999 lines (or CBSA system capacity)

What does this mean for Customs Brokers?

Cole International Inc. must now provide the full 10 digit Harmonized System code for each item detailed on the commercial/Canada Customs Invoice (CCI) prior to transmitting the information to Canada Border Services Agency (CBSA) for release. Each commodity has it’s own unique 10 digit HS Code and in some cases, requires a great deal of research and communication with the importer and/or vendor to determine the correct HS code.

We will be required to devote additional resources and time to process entries that contain multiple goods and/or part numbers.

What does this mean for Importers?

In order for Cole International to affect a release on your entries, we must have sufficient lead time to determine the proper HS Classification and the required trade data for each line of goods identified on any particular entry. We will require the entry information much sooner then we have in the past, so we will ask that you provide your information as soon as it becomes available.  If the commercial/Canada customs invoice is not available, we can use your Purchase Order, or any other documentation that provides enough detail for us to research your commodities appropriately to get this process started.

If you have any questions or concerns, please contact your Cole International Representative for assistance.  We will work with you to develop a process that will allow us to meet the January 1, 2013 deadline.

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À compter du 1er janvier 2013, les codes complets du Système harmonisé (SH) seront obligatoires pour une mainlevée douanière

 

Le Système harmonisé (SH) obligatoire, une initiative importante du gouvernement du Canada, consiste à obtenir la bonne information au bon moment afin de renforcer la capacité de l’Agence des services frontaliers du Canada (ASFC) à déterminer les menaces potentielles contre le Canada tout en facilitant la circulation transfrontalière des expéditions à faible risque.

Dans la foulée des phases précédentes de l’initiative Information préalable sur les expéditions commerciales (IPEC), les importateurs seront tenus d’indiquer le tarif des douanes lors de la transmission électronique des données commerciales préalables. Ainsi, à compter du 1er janvier 2013, un code du SH pour toutes les lignes jusqu’à un maximum de 999 lignes sera obligatoire pour toutes les demandes de mainlevée électroniques (SEA ou MDN) transmises au moyen de l’échange de données informatisé (EDI). Les demandes de mainlevée électroniques qui ne sont pas conformes au nombre minimal des codes du SH ci‑dessus seront rejetées et pourraient donner lieu à une sanction administrative pécuniaire.

Échéance pour l’application des exigences relatives au code du SH


Nombre de codes du SH exigés

Le 1er septembre 2011 Un minimum de 10 codes du SH
Le 1er février 2012 Un minimum de 20 codes du SH
Le 1er juin 2012 Un minimum de 30 codes du SH
Le 1er janvier 2013 un code du SH pour toutes les lignes jusqu’à un maximum de 999 lignes (soit la capacité du système de l’ASFC)

Qu’est-ce que cela signifie pour les courtiers en douanes?

Cole International Inc. doit désormais fournir le code complet du Système harmonisé à 10 chiffres pour chaque article détaillé sur la facture commerciale ou la facture des douanes canadiennes avant de transmettre l’information à l’Agence des services frontaliers du Canada (ASFC) pour la mainlevée. Chaque marchandise a son propre code du SH unique à 10 chiffres et, dans certains cas, nécessite beaucoup de recherche et de communication avec l’importateur ou le vendeur pour en déterminer le code du SH exact.

Cela étant, il nous faudra plus de temps et de ressources pour traiter les déclarations qui contiennent plusieurs marchandises ou numéros de pièce.

Qu’est-ce que cela signifie pour les importateurs?

Pour être en mesure d’obtenir la mainlevée relative à vos déclarations, Cole International doit les recevoir suffisamment d’avance pour leur attribuer la classification appropriée du SH et déterminer les données commerciales requises pour chaque ligne de facturation comprise dans la déclaration. Cela signifie que nous devrons recevoir les renseignements relatifs à la déclaration beaucoup plus tôt que ce que nous demandions avant. Nous demanderons donc que vous nous transmettiez l’information dès que vous l’avez en main. Si vous n’avez pas encore reçu la facture commerciale ou la facture des douanes canadiennes, nous pouvons utiliser votre bon de commande ou tout autre document qui comprend suffisamment de renseignements pour nous permettre de procéder aux recherches qui s’imposent relativement à vos marchandises et d’enclencher le processus.

Si vous avez des questions ou des préoccupations à ce sujet, n’hésitez pas à communiquer avec votre représentant de Cole International, qui se fera un plaisir de vous aider. Nous collaborerons ensemble pour mettre sur pied un processus qui nous permettra de respecter l’échéance du 1er janvier 2013.

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EOBR Regulations in Canada

One of the many benefits of attending industry conferences is the opportunity to discuss current trends and issues with colleagues. That was exactly the case earlier this month when I attended the CITT “Reposition 2012” conference in Halifax, NS to make a presentation on key performance indicators and performance metrics.
It was during one of these conversations that the subject of EOBR’s (electronic on-board recorders) came up. My colleague works for a leading asset-based Canadian motor carrier and quickly outlined her concerns over the potential impact for transportation companies, particularly as they relate to U.S. regulations.
Coincidentally, an excellent article on this subject in the October edition of Truck News reminded me of our conversation and provided some welcome insight into this evolving issue.
The gist of the Truck News report appears to be that we may not be seeing any definitive Canadian regulations on EOBR’s any time soon. Not because Canadian regulatory agencies and industry associations aren’t interested, but because of the one-step-forward, two-step-back progress experienced by the FMCSA (Federal Motor Carrier Safety Administration) in the U.S. since the issue of EOBR’s was first introduced.
EOBR’s will provide an electronic platform for enforcing compliance with HOS (hours-of-service) regulations, rather than the current manually-intensive paper systems. HOS and EOBR regulations have both endured their share of legal challenges in the U.S., resulting in changes which added to industry confusion. Nonetheless, the final rule for HOS in the U.S. related to commercial motor vehicles took effect earlier this year, and the FMCSA recently amended EOBR regulations pertaining to commercial motor vehicles manufactured after June 4, 2012 (compliant EOBR’s installed in vehicles manufactured prior to that date can continue to be used for the life of the vehicle). But since the intent of the FMCSA appears to be the continued expansion of EOBR’s to target carriers that do not comply with HOS rules, one might expect further revisions in future.
Where does that leave Canadian EOBR regulations? According to the Truck News article, some Canadian carriers have already adopted the use of EOBR’s voluntarily for monitoring performance standards and tracking hours-of-service compliance, but a Canadian standard has yet to be developed.
The CCMTA (Canadian Council of Motor Transport Administrators) has appointed a steering committee to work on the issue, and they are keenly aware of the many challenges encountered by the FMCSA. A primary concern for Canadian regulators will be development of a standard that meets safety, enforcement and jurisdictional needs across the country, but the steering committee also acknowledges it should ideally meet the requirements of U.S. regulators as well to avoid border-crossing issues.
While many shippers may regard EOBR’s as a “carrier issue”, motor carriers are looking at the bigger picture in terms of the potential impact on driver availability, labour costs, and their ability to provide timely delivery services for their customers. And that should make it an issue worth following for everyone involved.

Posted by: Laurie Turnbull, CITT, P.MM – Supply Chain Consultant, Cole International

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Customs Delays in Emerging Nations

The recent decision by the government of India to provide 24-hour Customs clearance services at major ocean ports and airports may come as a surprise to many in the Canadian  import/export community, especially since many of us take these services provided by CBSA (Canada Border Services Agency) in Canada for granted. It also serves as a reminder for Canadian organizations doing business in India that “due diligence” includes developing an understanding of all the various facets of supply chain management in foreign trading-partner countries, including Customs clearance.

In a high-tech industrialized nation such as Canada, 24-hour Customs clearance services are available at more than 20 ports across the country to support trade. Many transportation carriers, Ports, airports and international land border crossings operate around the clock, seven days a week and the inability to clear incoming shipments on a timely basis could result in significant backlogs at border points. This is particularly true of the daily trade flows between Canada and the United States, our largest trading partner.

India is not currently a Top 10 trading partner with Canada, but it is an emerging economy and one that Canada has been engaging with in free-trade talks since 2010. Both countries are hungry for trade and there are lots of opportunities for growth, as evidenced by the World Trade Organization report “Merchandise trade: leading exporters and importers, 2009” which lists Canada in 12th spot, responsible for 2.2% of merchandise trade, and India at #22, with 1.2% of merchandise trade.

Despite the common aspirations of importers and exporters in both countries however, there are many other factors to consider in terms of developing a successful trading relationship, and contrasts abound between the two nations. Canada has a population of approximately 34 million and a land mass of 9.9 million square km, compared to India with a population of over 1 billion and a land mass of 3.3 million square km. On the other hand, the trade balance between our two nations is relatively even. In 2010, Canada’s exports to India totaled $2.15 billion (CAD), while imports amounted to $2.12 billion (CAD).

While there are tremendous opportunities for grown in trade, Canadian importers and exporters should also be aware that there are differences in transportation infrastructure between the two countries that can impact the timeliness of shipping goods. A Canadian Services Coalition report in 2007 observed there are significant “infrastructure inadequacies in India when it comes to roads, rail, ports, and airports”. According to that report, “Most of India’s national highways are one lane and there is a lack of highways connecting rural areas to the economic hubs of the country.” In that respect, Canada’s infrastructure may have an advantage, at least in terms of its capacity to facilitate the movement of goods.

But the observation that “it can take up to 2 hours during rush hour to go the 30 km from Mumbai’s international airport to the heart of the city” is probably similar to that in Toronto on occasion! The point however is that not having a timely system for Customs clearance only adds to the potential for delay in a growing economy, and is a factor that importers and exporters should be aware of.

Posted by: Laurie Turnbull, CITT, P.MM – Supply Chain Consultant, Cole International

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