The Commerce Control List in all its glory. The Commerce Control List (CCL) is a critical part of export controls under the U.S. Export Administration Regulations (EAR). This webinar offers a comprehensive overview of the CCL, breaking down its structure, categories, and the nuances of classification. We’ll guide you through the essential steps to correctly determine the classification of items and provide tips on how to stay compliant with export regulations.
The Short Version
- We bill for our services under a written agreement on an hourly, fixed fee, or retainer basis.
- The type of billing we will apply to your engagement is determined collaboratively with you before you sign an agreement with us based on your needs.
- We will perform and bill for work for you under three circumstances:
- Your direct request or acceptance of our suggestions, or
- To respond to a request for response by a regulatory entity, such as US Customs, or
- To act in support of your Reasonable Care responsibilities under 19CFR 111.29, through our appropriate Due Diligence as we deem necessary.
- We will always ensure that the individuals performing work on your behalf are properly trained, knowledgeable, and credentialed as appropriate for the work performed.
- We will never bill you for work that is unnecessary, redundant, or inappropriate in application to your needs or in any way seek to recover “overhead” costs of our own operations from you.
- You will treat our efforts as valuable and agree to pay for those efforts in good faith.
Standardized Billing Documents
Welcome Packet
All billing terms and conditions are found within your Welcome Packet. Each Welcome Packet contains: an introduction to Star, a Project Detail Sheet, rate schedule, invoicing practices, accounts payable details, invoicing authorization, mutual confidentiality agreement, and terms and conditions of service. You may contact us via billing@starusa.org to request an executed copy of your Welcome Packet or other contracting documents at any time during your engagement with us.
Project Detail Sheet
The Project Detail Sheet (“PDS”) is the operative document for the scope of work or specific billing terms for an engagement. A PDS will describe the scope of work in sufficient detail to ensure that you are agreeing to the work you intend to purchase. The costs to you, whether fixed fee or hourly, will be identified in the PDS. If the engagement has a timeframe or start and stop dates, those dates will be identified. If you have specified any specific requirements, those will also be included.
Types Of Engagements We Offer
We offer multiple engagement types to accommodate any scale or budget, customized to meet your particular needs.
Hourly Engagements
For Hourly agreements, all work will be billed by the hour. Hourly rates are listed in the Welcome Packet, and we will always choose the combination of staff and rate that strikes the optimal balance between required expertise and cost to you.
Fixed Fee Engagements
This pricing model sets either a total fixed fee for the entire engagement or a fixed monthly fee. The fixed cost is negotiated with you at the beginning of a new engagement, or specific to a scope of work (PDS) for a sub-project within an otherwise hourly engagement. Fixed fee engagements may be invoiced in installments as work progresses or in whole after completion, at our discretion.
Retainer Engagements
Retainer agreements make our experts available to you on demand for a low fixed monthly fee, up to a monthly limit of total hours. Services are counted hourly against this fixed fee at our current rates until the limit is reached. Once the limit is reached, you have the option to request continued hourly work at our current rates or hold requests until the next monthly billing period begins.
Professional Fees & Staffing Considerations
We place high emphasis on the skill and efficiency of our team members. Regardless of the type of engagement, all work is performed by skilled and experienced in-house staff under non-disclosure.
Waste Not, Want Not
To ensure that our experts are not burdened with administrative tasks thereby increasing your cost, we actively seek to optimize the workload between our experts and your staff and will make recommendations as appropriate when you could in-house for cost savings. In such circumstances, we will offer to train your staff and provide work instructions for successful execution of the task with your pre-approval.
Factors Considered when Assigning Staff
The rate charged for our services is based on the complexity of the work. We also consider other factors, as appropriate, including: the novelty and difficulty of the issues involved; the skill or credentials required to do the work; the fee customarily charged by comparable firms for similar services; the value or measurable “ROI” of the work to you; the operational risk involved in servicing the request, if any; time constraints imposed by you or the circumstances; and the nature and length of our professional relationship with you.
Cost Efficiency
We will always seek to perform your work cost efficiently. This does not mean, however, that we will necessarily assign a person with the lowest hourly rate. First and foremost, a person with the appropriate level of skill and understanding will always be assigned to your work. Under some circumstances, persons with higher hourly rates may also be assigned to provide specialized skills, to meet time constraints imposed by you or the circumstances, to seek to perform the work at a lower overall cost to you, or because of other material factors. When billing time to you under an hourly engagement, our staff will bill time in quarter-hour increments to optimize cost efficiency.
Hourly Rate Adjustments
Our hourly rates are subject to review and adjustment from time to time, at least annually, based on any factors that would necessitate a change. In particular, our rates are adjusted to account for market factors that would otherwise impede our ability to ensure the highest quality experts are available to you at all times. Any adjustments deemed necessary apply to all of our clients and we do not offer “preferred”, “contracted”, multi-year, or otherwise discounted or locked rates to any clients to ensure fairness in access to our services.
Travel Time
When our experts are traveling on your behalf, we will bill you their regular hourly rate for all travel time during normal business hours. However, our staff will never “double bill”: if the person traveling is performing work for a different client while in transit, only that client will be billed, and you will not. An expert in transit will always prioritize your work first, if available and appropriate to the circumstances.
Expenses
In addition to fees for our services, our invoices may include out-of-pocket expenses (e.g., filing fees, overnight courier fees, travel, and postage) in connection with performing work on your behalf. Out-of-pocket expenses incurred will be billed at our cost on your next regular invoicing cycle. Specific considerations for how we will limit charges for expense items related to travel are listed in your Welcome Packet.
Your Commitment
We appreciate that you understand the value of our work performed on your behalf. Everything we do is customized to your needs, and applicable only to you. Your payment within the invoicing terms ensures that we will continue assigning our staff to your work. We will suspend efforts on your behalf with written notice by email if you have past-due balances that you are not actively working to resolve with our billing team.
Thank You
We sincerely appreciate your understanding and commitment to our Fairness in Billing Policy. As our valued partner, your support is instrumental to our success. Thank you for being an essential part of our journey.