Kenji Tanaka

21h ago11 likes

Watch the knock-on for anyone shipping under an FTA with a direct-transport rule. Two of our Japan-EU consignments transhipped at a port that was not on the original routing and the certificate needed a non-manipulation statement we had not budgeted time for. Longer transit is the visible cost; the paperwork is the one that bites.

1d ago2 likes

It came up once in their information request; we answered with the heading note reference and it went quiet. Keep the response narrow.

2d ago12 likes

We defended 9032 for smart AC controllers last year. The argument that held: the learning algorithm and app are means of setting the setpoint, not a separate function, the device still exists to maintain temperature automatically, which is the 9032 definition. GRI 3(b) never came into play because we argued it's not a composite-function device at all. Look up NY N305789, similar fact pattern, sustained.

5d ago4 likes

Second the headroom point, we certify nothing under 5 points of margin after getting burned by a steel price swing mid-year.