CSMS Message: 97-000791

TO : ALL ABI BROKERS.

FROM : CARLA ZZ-DONOFRIO

SUBJECT : ELVIS-PHILIPPINES

DATE : 08/20/97

AUGUST 13, 1997

SPE-2 FO:TC:I:E CDD
CATEGORY: TEX

TO : ALL PORT DIRECTORS, CUSTOMS MANAGEMENT CENTER
(CMC) DIRECTORS AND STRATEGIC TRADE CENTER (STC)
DIRECTORS

FROM : DIRECTOR, TRADE COMPLIANCE

PASS TO : ALL IMPORT SPECIALISTS, NATIONAL IMPORT
SPECIALISTS, ENTRY OFFICERS, INSPECTORS AND
INTERNATIONAL TRADE SPECIALISTS, BROKERS AND
OTHER INTERESTED PARTIES

SUBJECT : TBT-97-083-CONSOLIDATION AND AMENDMENT OF EXPORT
VISA REQUIREMENTS TO INCLUDE THE ELECTRONIC VISA
INFORMATION SYSTEM FOR CERTAIN COTTON, WOOL,
MAN-MADE FIBER, SILK BLEND AND OTHER VEGETABLE
FIBER TEXTILES AND TEXTILE PRODUCTS PRODUCED OR
MANUFACTURED IN PHILIPPINES

COUNTRY : PHILIPPINES

BACKGROUND :

A CITA DIRECTIVE DATED, DECEMBER 24, 1996, DIRECTED U.S.
CUSTOMS TO PROHIBIT, EFFECTIVE ON SEPTEMBER 1, 1997, ENTRY
INTO CUSTOMS TERRITORY OF THE UNITED STATES FOR CONSUMPTION
AND WITHDRAWAL FROM WAREHOUSE OF CERTAIN COTTON, WOOL, MAN-
MADE FIBER, SILK BLEND AND OTHER VEGETABLE FIBER TEXTILES
AND TEXTILE PRODUCTS, IN CATEGORIES 300-369, 400-469, 600-
670 AND 831-859, INCLUDING PART CATEGORIES AND MERGED
CATEGORIES (BUT NOT CATEGORIES 355, 356, 655, 656, 455, 371
AND 671), AND WHICH ARE NOT ELIGIBLE FOR EXEMPTIONS NOTED IN
THE EXEMPT CERTIFICATION REQUIREMENTS BELOW, PRODUCED OR
MANUFACTURED IN THE PHILIPPINES AND EXPORTED ON AND AFTER
SEPTEMBER 1, 1997 FOR WHICH THE GOVERNMENT OF THE
PHILIPPINES HAS NOT ISSUED AN APPROPRIATE EXPORT VISA AND
ELECTRONIC VISA INFORMATION SYSTEM (ELVIS) TRANSMISSION
FULLY DESCRIBED BELOW. SHIPMENTS COVERING MERCHANDISE IN
CATEGORIES 800-810 AND 863-899 DO NOT REQUIRE A VISA.
HOWEVER, SHOULD ADDITIONAL CATEGORIES, MERGED CATEGORIES OR
PART CATEGORIES BE ADDED TO OR CHANGED IN THE BILATERAL
AGREEMENT OR BECOME SUBJECT TO IMPORT QUOTAS, THE ENTIRE
CATEGORY OR CATEGORIES SHALL BE AUTOMATICALLY INCLUDED IN
THE COVERAGE OF THE VISA ARRANGEMENT. MERCHANDISE EXPORTED
ON OR AFTER THE DATE THE CATEGORY IS ADDED TO OR CHANGED IN
THE AGREEMENT, OR BECOMES SUBJECT TO IMPORT QUOTAS, SHALL
REQUIRE A VISA AND ELVIS TRANSMISSION.

A VISA MUST ACCOMPANY EACH COMMERCIAL SHIPMENT OF THE
AFOREMENTIONED TEXTILE PRODUCTS. A CIRCULAR STAMPED MARKING
IN BLUE INK WILL APPEAR ON THE FRONT OF THE ORIGINAL
COMMERCIAL INVOICE. THE ORIGINAL VISA SHALL NOT BE STAMPED
ON DUPLICATE COPIES OF THE INVOICE. THE ORIGINAL INVOICE
WITH THE ORIGINAL VISA STAMP WILL BE REQUIRED TO ENTER THE
SHIPMENT INTO THE UNITED STATES. DUPLICATES OF THE INVOICE
AND-OR VISA MAY NOT BE USED FOR THIS PURPOSE.

EACH VISA STAMP SHALL INCLUDE THE FOLLOWING INFORMATION:

1. THE VISA NUMBER. THE VISA NUMBER SHALL BE IN THE STANDARD
NINE DIGITS AND LETTERS, BEGINNING WITH ONE NUMERIC DIGIT
FOR THE LAST DIGIT OF THE YEAR OF EXPORT, FOLLOWED BY THE
TWO CHARACTER ALPHA COUNTRY CODE SPECIFIED BY THE
INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO) (THE
CODE FOR THE PHILIPPINES IS ``PH''), AND A SIX DIGIT NUMERIC
SERIAL NUMBER IDENTIFYING THE SHIPMENT; E.G., 7PH123456.

2. THE DATE OF ISSUANCE. THE DATE OF ISSUANCE SHALL BE THE
DAY, MONTH AND YEAR ON WHICH THE VISA WAS ISSUED.

3. THE ORIGINAL SIGNATURE OF THE ISSUING OFFICIAL OF THE
GOVERNMENT OF THE PHILIPPINES.

4. THE CORRECT CATEGORY(S), PART CATEGORY(S), MERGED
CATEGORY(S), QUANTITY(S) AND UNIT(S) OF QUANTITY IN THE
SHIPMENT IN THE UNIT(S) OF QUANTITY PROVIDED FOR IN THE U.S.
DEPARTMENT OF COMMERCE CORRELATION AND IN THE U.S.
HARMONIZED TARIFF SCHEDULES OF THE UNITED STATES ANNOTATED (
HTS), E.G., ``CAT. 340 - 510 DZ.'' ANNEX B LISTS ALL THE
PART-CATEGORY AND MERGE CATEGORY VISAS REQUIRED FOR ENTRY.

QUANTITIES MUST BE STATED IN WHOLE NUMBERS. DECIMALS OR
FRACTIONS WILL NOT BE ACCEPTED. PRODUCTS COVERED BY MERGED
CATEGORY QUOTAS MUST BE ACCOMPANIED BY EITHER A MERGED
CATEGORY VISA OR THE CORRECT CATEGORY VISA CORRESPONDING TO
THE ACTUAL SHIPMENT (E.G., QUOTA CATEGORY 333-334 MAY BE
VISAED AS ``CATEGORY 333-334'' OR IF THE SHIPMENT CONSISTS
SOLELY OF CATEGORY 333 MERCHANDISE, THE SHIPMENT MAY BE
VISAED AS ``CATEGORY 333,'' BUT NOT AS ``CATEGORY 334'').

U.S. CUSTOMS SHALL NOT PERMIT ENTRY IF THE SHIPMENT DOES NOT
HAVE A VISA, OR IF THE VISA NUMBER, DATE OF ISSUANCE,
SIGNATURE, CATEGORY, QUANTITY OR UNITS OF QUANTITY ARE
MISSING, INCORRECT OR ILLEGIBLE, OR HAVE BEEN CROSSED OUT OR
ALTERED IN ANY WAY. IF THE QUANTITY INDICATED ON THE VISA
IS LESS THAN THAT OF THE SHIPMENT, ENTRY SHALL NOT BE
PERMITTED. IF THE QUANTITY INDICATED ON THE VISA IS MORE
THAN THAT OF THE SHIPMENT, ENTRY SHALL BE PERMITTED
AND ONLY THE AMOUNT ENTERED SHALL BE CHARGED TO ANY
APPLICABLE QUOTA.

IF THE VISA IS NOT ACCEPTABLE THEN A NEW VISA MUST BE
OBTAINED FROM THE PHILIPPINE GOVERNMENT OR A VISA WAIVER
ISSUED BY THE U.S. DEPARTMENT OF COMMERCE AT THE REQUEST OF
THE PHILIPPINE GOVERNMENT AND PRESENTED TO THE U.S. CUSTOMS
SERVICE BEFORE ANY PORTION OF THE SHIPMENT WILL BE RELEASED.
A VISA WAIVER MAY BE ISSUED BY THE DEPARTMENT OF COMMERCE AT
THE REQUEST OF THE EMBASSY IN WASHINGTON FOR THE GOVERNMENT
OF THE PHILIPPINES. THE WAIVER, IF USED, ONLY WAIVES THE
REQUIREMENT TO PRESENT A VISA AT ENTRY. IT DOES NOT WAIVE
ANY QUOTA REQUIREMENTS. VISA WAIVERS WILL ONLY BE ISSUED
FOR CLASSIFICATION PURPOSES OR FOR ONE TIME SPECIAL PURPOSE
SHIPMENTS THAT ARE NOT PART OF AN ONGOING COMMERCIAL
ENTERPRISE.

IF THE VISAED INVOICE IS DEFICIENT, THE U.S. CUSTOMS SERVICE
WILL NOT RETURN THE ORIGINAL DOCUMENT AFTER ENTRY OR
ATTEMPTED ENTRY, BUT WILL PROVIDE THE IMPORTER A CERTIFIED
COPY OF THAT VISAED INVOICE FOR USE IN OBTAINING A NEW
CORRECT ORIGINAL VISAED INVOICE OR A VISA WAIVER.

THE COMPLETE NAME AND ADDRESS OF A COMPANY ACTUALLY INVOLVED
IN THE MANUFACTURING PROCESS OF THE TEXTILE PRODUCT COVERED
BY THE VISA SHALL BE PROVIDED ON THE TEXTILE VISA DOCUMENT.

IF A SHIPMENT FROM THE PHILIPPINES HAS BEEN ALLOWED ENTRY
INTO THE COMMERCE OF THE UNITED STATES WITH EITHER AN
INCORRECT VISA OR NO VISA, AND REDELIVERY IS REQUESTED BUT
CANNOT BE MADE, THE SHIPMENT WILL BE CHARGED TO THE CORRECT
CATEGORY LIMIT WHETHER OR NOT A REPLACEMENT VISA OR VISA
WAIVER IS PROVIDED.

ELVIS REQUIREMENTS:

A. EACH ELVIS MESSAGE WILL INCLUDE THE FOLLOWING
INFORMATION:

I. THE VISA NUMBER. THE VISA NUMBER SHALL BE IN THE
STANDARD NINE DIGITS AND LETTERS, BEGINNING WITH ONE NUMERIC
DIGIT FOR THE LAST DIGIT OF THE YEAR OF EXPORT, FOLLOWED BY
THE TWO CHARACTER ALPHA COUNTRY CODE SPECIFIED BY THE
INTERNATIONAL ORGANIZATION FOR STANDARDIZATION (ISO) (THE
CODE FOR THE PHILIPPINES IS ``PH''), AND A SIX DIGIT NUMERIC
SERIAL NUMBER IDENTIFYING THE SHIPMENT; E.G., 7PH123456.

II. THE DATE OF ISSUANCE. THE DATE OF ISSUANCE SHALL BE THE
DAY, MONTH AND YEAR ON WHICH THE VISA WAS ISSUED.

III. THE CORRECT CATEGORY(S), MERGED CATEGORY(S), PART
CATEGORY(S), QUANTITY(S) AND UNIT(S) OF QUANTITY OF THE
SHIPMENT IN UNIT(S) OF QUANTITY PROVIDED FOR IN THE U.S.
DEPARTMENT OF COMMERCE CORRELATION AND IN THE HARMONIZED
TARIFF SCHEDULE OF THE UNITED STATES, ANNOTATED, OR
SUCCESSOR DOCUMENTS.

IV. THE MANUFACTURER ID NUMBER (MID). THE MID SHALL BEGIN
WITH ``PH,'' FOLLOWED BY THE FIRST THREE CHARACTERS FROM
EACH OF THE FIRST TWO WORDS OF THE NAME OF THE MANUFACTURER,
FOLLOWED BY THE LARGEST NUMBER ON THE ADDRESS LINE UP TO THE
FIRST FOUR DIGITS, FOLLOWED BY THREE LETTERS FROM THE CITY
NAME.

B. ENTRY OF A SHIPMENT SHALL NOT BE PERMITTED:

I. IF AN ELVIS TRANSMISSION HAS NOT BEEN RECEIVED FOR THE
SHIPMENT FROM THE PHILIPPINES;

II. IF THE ELVIS TRANSMISSION FOR THAT SHIPMENT IS MISSING
ANY OF THE FOLLOWING:

A. VISA NUMBER
B. CATEGORY OR PART CATEGORY
C. QUANTITY
D. UNIT OF MEASURE
E. DATE OF ISSUANCE
F. MANUFACTURER ID NUMBER;

III. IF THE ELVIS TRANSMISSION FOR THE SHIPMENT DOES NOT
MATCH THE INFORMATION SUPPLIED BY THE IMPORTER, OR THE
CUSTOMS BROKER ACTING AS AN AGENT ON BEHALF OF THE IMPORTER,
WITH REGARD TO ANY OF THE FOLLOWING:

A. VISA NUMBER
B. CATEGORY OR PART CATEGORY
C. UNIT OF MEASURE;

IV. IF THE QUANTITY BEING ENTERED IS GREATER THAN THE
QUANTITY TRANSMITTED; OR,

V. IF THE VISA NUMBER HAS PREVIOUSLY BEEN USED, OR CANCELED,
EXCEPT IN THE CASE OF A SPLIT SHIPMENT OR IF ANY ENTRY HAS
ALREADY BEEN MADE USING THE VISA NUMBER.

C. A NEW, CORRECT ELVIS TRANSMISSION FROM THE COUNTRY OF
ORIGIN IS REQUIRED BEFORE A SHIPMENT THAT HAS BEEN DENIED
ENTRY FOR ONE OF THE CIRCUMSTANCES MENTIONED IN B.I-V WILL
BE RELEASED.

D. A NEW, CORRECT ELVIS TRANSMISSION FROM THE COUNTRY OF
ORIGIN IS REQUIRED FOR ENTRIES MADE USING A VISA WAIVER
UNDER THE PROCEDURE DESCRIBED ABOVE. VISA WAIVERS WILL ONLY
BE CONSIDERED FOR CLASSIFICATION PURPOSES OR FOR ONE TIME
SPECIAL PURPOSE SHIPMENT THAT IS NOT PART OF AN ONGOING
COMMERCIAL ENTERPRISE OR FOR LEGITIMATE CLASSIFICATION
DISPUTES.

E. SHIPMENTS WILL NOT BE RELEASED FOR FORTY-EIGHT HOURS IN
THE EVENT OF A SYSTEM FAILURE. IF SYSTEM FAILURE EXCEEDS
FORTY-EIGHT HOURS, FOR THE REMAINING PERIOD OF THE SYSTEM
FAILURE THE U.S. CUSTOMS SERVICE WILL RELEASE SHIPMENTS ON
THE BASIS OF THE PAPER VISAED DOCUMENT.

F. IF A SHIPMENT FROM THE PHILIPPINES IS ALLOWED ENTRY INTO
THE COMMERCE OF THE UNITED STATES WITH AN INCORRECT VISA, NO
VISA, AN INCORRECT ELVIS TRANSMISSION, OR NO ELVIS
TRANSMISSION, AND REDELIVERY IS REQUESTED BUT CANNOT BE
MADE, THE SHIPMENT WILL BE CHARGED TO THE CORRECT CATEGORY
LIMIT WHETHER OR NOT A REPLACEMENT VISA OR WAIVER IS
PROVIDED OR A NEW ELVIS MESSAGE IS TRANSMITTED.

G. THE U.S. CUSTOMS SERVICE WILL PROVIDE PHILIPPINE
AUTHORITIES WITH A REPORT CONTAINING INFORMATION ON VISA
UTILIZATION THAT CAN BE ACCESSED AT ANY TIME. THIS REPORT
WILL CONTAIN:

A. VISA NUMBER
B. CATEGORY NUMBER
C. QUANTITY CHARGED TO QUOTA
D. UNIT OF MEASUREMENT
E. ENTRY NUMBER
F. ENTRY LINE NUMBER

EXEMPT CERTIFICATION REQUIREMENTS:

A. TEXTILES AND TEXTILE ARTICLES PROVIDED FOR BELOW, AND IN
ANNEX A ATTACHED, WILL BE EXEMPT FROM LEVELS OF RESTRAINT
QUOTAS, AND VISA AND ELVIS REQUIREMENTS IF THEY ARE
CERTIFIED, PRIOR TO THE SHIPMENT LEAVING THE PHILIPPINES, BY
THE PLACING OF THE ORIGINAL RECTANGULAR-SHAPED STAMPED
MARKING IN BLUE INK ON THE FRONT OF THE ORIGINAL COMMERCIAL
INVOICE. THE ORIGINAL EXEMPT CERTIFICATION SHALL NOT BE
AFFIXED TO DUPLICATE COPIES OF THE INVOICE. THE ORIGINAL
COPY OF THE INVOICE WITH THE ORIGINAL EXEMPT CERTIFICATION
WILL BE REQUIRED TO ENTER THE SHIPMENT INTO THE UNITED
STATES. DUPLICATE COPIES OF THE INVOICE AND-OR EXEMPT
CERTIFICATION MAY NOT BE USED.

1. HANDWOVEN AND HANDLOOMED FABRICS OF THE COTTAGE INDUSTRY

2. HANDMADE ARTICLES AND GARMENTS OF HANDWOVEN AND
HANDLOOMED FABRIC: ALL ITEMS MUST BE CUT, SEWN, OR OTHERWISE
FABRICATED BY HAND IN ORDER TO QUALIFY FOR THIS EXEMPTION.
THEY MAY NOT INCLUDE MACHINE STITCHING.

3. TRADITIONAL FOLKLORE HANDICRAFT PRODUCTS: ONLY PRODUCTS
WHICH FALL WITHIN THE DEFINITION OF ``PHILIPPINE ITEMS'',
QUALIFY FOR THIS EXEMPTION PROVIDED THAT THEY ARE CUT, SEWN,
OR OTHERWISE FABRICATED BY HAND. THEY MAY NOT INCLUDE
MACHINE STITCHING.

PHILIPPINE ITEMS-PHILIPPINE TRADITIONAL FOLKLORE HANDICRAFT
TEXTILE PRODUCTS ARE TRADITIONAL PHILIPPINE PRODUCTS, CUT,
SEWN OR OTHERWISE FABRICATED BY HAND IN COTTAGE UNITS OF THE
COTTAGE INDUSTRY. THE FOLLOWING IS THE AGREED UPON LIST OF
SUCH ITEMS:

1. BATIK AND HABLON FABRICS-HAND WOVEN FABRICS OF THE
COTTAGE INDUSTRY.
2. BANAUE CLOTH-COTTON HANDLOOM FABRIC IN MULTI-
COLORS.
3. OTHER HAND WOVEN AND HANDLOOM FABRICS OF THE
COTTAGE INDUSTRY.
4. ARTICLES AND GARMENTS MADE BY HAND FROM HAND WOVEN
AND HAND LOOMED FABRICS.

B. REQUIREMENTS FOR EXEMPT CERTIFICATION STAMP: EACH EXEMPT
CERTIFICATION STAMP WILL INCLUDE THE FOLLOWING INFORMATION:

I. DATE OF ISSUANCE.
II. SIGNATURE OF ISSUING OFFICIAL.
III. THE BASIS FOR THE EXEMPTION SHALL BE NOTED AS:

A. HANDWOVEN FABRIC OR HANDLOOMED FABRIC (WHICHEVER IS
APPROPRIATE).
B. HANDMADE TEXTILE PRODUCTS.
C. THE NAME OF THE PARTICULAR TRADITIONAL FOLKLORE
HANDICRAFT PRODUCT (PHILIPPINE ITEMS), E.G. ``BANAUE
CLOTH.''

SHIPMENTS NOT REQUIRING VISAS OR EXEMPT CERTIFICATIONS:

MERCHANDISE IMPORTED FOR THE PERSONAL USE OF THE IMPORTER
AND NOT FOR RESALE, REGARDLESS OF VALUE, AND PROPERLY MARKED
COMMERCIAL SAMPLE SHIPMENTS VALUED AT U.S. $250 OR LESS DO
NOT REQUIRE A VISA, ELVIS TRANSMISSION OR EXEMPT
CERTIFICATION FOR ENTRY AND SHALL NOT BE CHARGED TO
AGREEMENT LEVELS.

OTHER PROVISIONS:

EXCEPT AS PROVIDED IN THE PARAGRAPH ABOVE, ANY SHIPMENT
WHICH REQUIRES A VISA BUT WHICH IS NOT ACCOMPANIED BY A
VALID AND CORRECT VISA AND ELVIS TRANSMISSION IN ACCORDANCE
WITH THE FOREGOING PROVISIONS, SHALL BE DENIED ENTRY BY THE
GOVERNMENT OF THE UNITED STATES OF AMERICA UNLESS THE
GOVERNMENT OF THE PHILIPPINES AUTHORIZES THE ENTRY AND ANY
CHARGES TO THE AGREEMENT LEVELS.

AN INVOICE MAY COVER VISAED MERCHANDISE OR EXEMPT
CERTIFICATION MERCHANDISE, BUT NOT BOTH.

THE VISA AND EXEMPT CERTIFICATION STAMPS REMAINS UNCHANGED.

THE FOLLOWING ARE THE ESTABLISHED MERGED CATEGORIES:

331-631
333-334
338-339
340-640
341-641
342-642
347-348
351-651
352-652
359-C-659-C
359-O-659-O
445-446
638-639
645-646
647-648

THE FOLLOWING ARE THE ESTABLISHED PART CATEGORIES:

359-C COTTON OVERALLS AND COVERALLS: ONLY HTS NUMBERS
6103.42.2025, 6103.49.8034, 6104.62.1020, 6104.69.8010,
6114.20.0048, 6114.20.0052, 6203.42.2010, 6203.42.2090,
6204.62.2010, 6211.32.0010, 6211.32.0025 AND 6211.42.0010.

359-O OTHER: ALL HTS NUMBERS EXCEPT THOSE IN CATEGORY 359-C.

369-S SWIMWEAR: ONLY HTS NUMBER 6307.10.2005.

369-O OTHER: ALL HTS NUMBERS EXCEPT THOSE IN CATEGORY 369-S.

659-C MAN-MADE FIBER OVERALLS AND COVERALLS: ONLY HTS
NUMBERS 6103.23.0055, 6103.43.2020, 6103.43.2025,
6103.49.2000, 6103.49.8038, 6104.63.1020, 6104.63.1030,
6104.69.1000, 6104.69.8014, 6114.30.3044, 6114.30.3054,
6203.43.2010, 6203.43.2090, 6203.49.1010, 6203.49.1090,
6204.63.1510, 6204.69.1010, 6210.10.9010, 6211.33.0010,
6211.33.0017 AND 6211.43.0010.

659-H HATS: ONLY HTS NUMBERS 6502.00.9030, 6504.00.9015,
6504.00.9060, 6505.90.5090, 6505.90.6090, 6505.90.7090 AND
6505.90.8090.

659-O OTHER: ALL HTS NUMBERS EXCEPT THOSE IN CATEGORIES 659-
C AND 659-H.

669-P POLY BAGS: ONLY HTS NUMBERS 6305.32.0010,
6305.32.0020, 6305.33.0010, 6305.33.0020 AND 6305.39.0000.

669-O OTHER: ALL HTS NUMBERS EXCEPT THOSE IN CATEGORY 669-P.

670-L LUGGAGE: ONLY HTS NUMBERS 4202.12.8030, 4202.12.8070,
4202.92.3020, 4202.92.3030 AND 4202.92.9025.

670-O OTHER: ALL HTS NUMBERS EXCEPT THOSE IN CATEGORY 670-L.

ACTION:

THIS TBT FORMALIZES THE AGREEMENT BETWEEN THE U.S.
GOVERNMENT AND THE GOVERNMENT OF THE PHILIPPINES TO AMEND
THE EXISTING VISA ARRANGEMENT FOR TEXTILE PRODUCTS, PRODUCED
OR MANUFACTURED IN PHILIPPINES AND EXPORTED ON AND AFTER
SEPTEMBER 1, 1997. THE AMENDED ARRANGEMENT CONSOLIDATES
EXISTING AND NEW PROVISIONS OF THE EXPORT VISA ARRANGEMENT,
INCLUDING PROVISIONS FOR THE ELECTRONIC VISA INFORMATION
SYSTEM (ELVIS).

INFORMATION:

IF YOU HAVE ANY QUESTIONS CONCERNING THIS TELEX, DON'T
HESITATE TO CONTACT CARLA D'ONOFRIO AT (202) 927-0424, JUNE
PERGOLA AT (202) 927-0705, OR BOB DORSETT AT (202) 927-7002,
TRADE COMPLIANCE.

PHILIP METZGER