Timeless Lessons in International Trade from an Industry Pioneer

Machine Automated Transcript: Hey everyone. Well, as you can tell, I’m starting the show off here because, again, we’re missing Andy here a little bit. He’s still transitioning into his new job, and so he’s he’s still working through that, but we promise he’ll still be. He’ll come back with us here pretty soon. We already had some recordings scheduled. And I thought, Okay, well, maybe I’ll tap into our well of previous hosts that we’ve had. And so I went ahead and asked our subject matter expert for global Training Center who you all know as Renee cucarelli, or as How does Andy say that Renee chicarelli or something like, he’s getting close so and Renee cucarelli, so is joining me, and she’s co hosting here today. I didn’t want to, like reschedule this recording, because I got really excited to try and get this person on the show, which is Tom Gould, and y’all have heard him before on our show. He’s been on maybe a couple of times, and then we probably caught up with him a time or two at a conference, but I didn’t want to skip this opportunity for several reasons. We we were getting to talk internally. Andy and I about, you know, just how Tom has when he was at Flexport, and then prior to that, with, like, center Travis and throughout his career. And I thought, hey, this is a good time for us to just hit him up and see if we can, we can get him on the show. So, so here we are, and Renee, I guess you’ve known Tom also in the past, through your career, correct? Yeah,

I met him at my one of my previous jobs. Teledyne, he trained us on ace, and it was awesome training. I always considered Tom like the ACE master, so, but he’s far more than that, believe me,

awesome, yeah, yeah, yeah. So Tom Welcome to the show again, just so that you we can introduce everybody. You to everybody, I guess I should say Welcome and thank you for joining us here again. Awesome. Thank you. So let’s start with that I did go through, and I talked a little bit about how you were your progression. I mean, I think I remember meeting you, maybe initially, a long time ago, just in passing, nothing formal back when you were at center and Travis. And then you, obviously, everybody knows that you were at Flexport year the last few years, and now you’re, you’re transitioning over into a consulting firm, your own consulting firm, where you’ll be helping clients do everything in trade. But can you tell us a little bit more about that and how you’ve progressed through your career and in trade. Sure,

you know, I fell into the industry, just like many of other people in the industry. I In the early days of the IBM PC. I was automating law firms. My dad was a lawyer, and he said he wanted to replace his typewriters with computers, and I helped him do that. And I actually kind of started a little business on my own where I was helping all of his friends automate their businesses. And while I was doing that, by chance, I landed at a law firm, steinshock Shostak and O’Hara that specialized in customs law. And I went there, and I brought computers into the firm. Taught their people how to use them, just for the basics, but then I started working on some more client related issues. For example, I helped them as they as they were doing research. This was before Cross was available for rulings. They had rulings research that was done, and I helped them to automate that process. Also helped them with building some databases for things like protests and so forth. And I spent some time there. After I left that law firm, I went to work at a software company that did customs compliance. Software companies no longer around. They were sold to another company, but I spent a little bit of time there, kind of as their subject matter expert, helping them with understanding the compliance aspect of the data that they were collecting for clients. Spent a little bit of time at one of the large, big four consulting firms, again, in their trade and customs practice. And then I really decided that I wanted to go out on our, on their on my own, and I decided to go out on my own because working at the law firm, working at the software company and the consulting firm, what I realized was that there were not a lot of people out there that were providing advice to companies on how to save on duties, but at the. Same time how to not get in trouble. So this was in the early days of NAFTA and some of the other free trade agreements, where companies were trying to take advantage of the free trade agreements, but they just didn’t have an understanding of the intricacies of how a product qualifies for a free trade agreement. While I was doing that, I also learned a lot about classification and under you know, understood the importance of classification, not just for classifying products, but also classification under free trade agreements and for PGAS and other purposes. So I helped a lot of companies with that. And one of the themes that you’ll see throughout my entire career is data. Right? I was always enamored by the data that was available, the data that was used by traders, and I always saw the value of the data, and so a lot of what I was doing was helping companies with understanding the opportunities that were available for them and the risks that were out there that they needed to know about by looking at the data. While I was on my own, I also got involved with customs, on an advisory committee, the trade support network, and that’s where I learned a lot about ace. And I know Renee, we talked about some of the training that I’ve done on ace. And so while I was consulting, I was helping a lot of companies with their ACE data and getting their ACE data and analyzing their ACE data. And so then I started helping on the other side as well. Mainly it was somewhat because of clients wanted to get access to more data. So I got involved on the trade support network. I was involved in the trade support network for many years. I’m actually still involved. And while I was at the trade support network, that’s where I met Lee Sandler, and Lee invited me to dinner one one time I remember and and asked me to join the firm. And I was like, you know, you know that I’m not a lawyer. And he said, Yeah, we have non lawyers working at the firm. Anyways, I when I it took them a while to convince me, but after a few years, they finally convinced me to join the firm. And I was really doing the same thing, whether I was on my own or whether I was at at Sandler Travis. And I really decided to join the firm at Sandler Travis because I was working with larger companies. They had more companies. I actually had more business that I could handle. So I needed support, and that was an easy way for me to do that was by joining the firm. While I was at Sandler Travis. I actually, before I was at Sandler Travis, I had actually worked with Ryan Peterson, the founder of Flexport, when he was originally starting his company. But while I was at Sandler Travis, Flexport hired Sandler Travis to do a mock broker audit. And so I had an opportunity to do that audit and to learn about the the business and really learn the business model and what they were doing. And I really liked that. So I decided to go back to or go go to, I’m sorry, to go to Flexport. I brought I started up their trade advisory practice. Worked in their operations team. I oversaw their

compliance team. And while I was there, I was also appointed to the customs commercial operations advisory committee, or coac, by secretaries Mayorkas and Yellen and I currently serve on the coac, and am helping to provide insight and guidance to customs on commercial operations. So that’s kind of a short, short version of my Yeah, that is,

if you Google Tom Gould, you’ll see that there’s an executive producer of love island with the same name.

I didn’t know that. That’s funny. I didn’t even know that. It’s

just a little fun fact, I got sucked into watching Love Love island with my daughter a couple times. It’s super interesting. It’s work. It’s like the Bachelor on 20. So anyway, Tom Gould, the executive producer. So that shows you he you know Tom Gould, that name, they go higher, they go farther, they go. But I’ve noticed in your LinkedIn profile that you generally have two jobs going at once. Tom, is that true?

I’ve often had multiple jobs. You know, as a consultant, you wear many hats, right? I do what my clients need for me to do. And you know, if that means that I have to wear multiple hats, I wear multiple hats, but you know, primarily my job has been either advising my clients, who could be importers or brokers or other people involved in international trade, or advising the government, you know, on how to better do their job in dealing with companies that trade internationally. Yeah,

that’s, well, I mean, you have so much background, and like you said, the data is what drives the compliance, the current, you know, that continuous circle that I’ve always talked about is, you know, you find an error, you get a solution, you update your SOP, you. Change your automation, and then, you know, the circle just continues. But that’s all to me, driven by data too. If you don’t have

it is, yeah, it is. And with today’s machine learning and artificial intelligence, there’s a lot more opportunity to analyze the data in different ways and analyze more data. You know, as a human, we can only look at so much data and make decisions based on what we see, but if we can leverage the power of these computers, we can be looking at a lot more data and making bigger, better decisions for our clients or for the companies that we work with. Yeah,

more more advanced, more forecasting. Yeah, exactly. I noticed. Did you work at the there’s a law firm in San Diego. Oh,

is this your group? Yeah, this or was one of my was one of my clients when I went out, when I went out on my own, I’ve often worked with law firms. I’ve worked with a number of the of the lawyers that specialize in customs and international trade. They, many of them have come to me as either as

backup, meaning they had more work and they needed somebody else to help them out with but also as a, you know, because I had different insight than they did. For example, when you talk to customs lawyers, most of them don’t have the knowledge of like the day to day operation of a brokerage. And so what does it mean when we’re filing a specific type of an entry, and how is the data structured when that information is transmitted to customs? So I’ve often had customs lawyers come to me and ask questions regarding this very detailed specifics of operating as a customs broker,

that’s great. So if I were coming to you for consulting, or, you know, I wanted to know what you what we know data is one of your expert areas, but, and I don’t want to put you on the spot, but what are your top three expert areas for our listeners that, hey, I know I can help people.

So I would say one of the areas that I’ve specialized in and been known for over the years is retail products. So wearing apparel, footwear, textiles, the rule the duty rates are very high and the rules are very complex. So companies have often sought out my advice when looking at the complex aspects of global trade, so retail is one area that I would say of the top three areas. The other area, that’s an area that that I often get questions on, is some of the some of the different types of duties that are applied to products today. So we’re talking about things like the section 301, duties on products from China. Section 232, on steel and aluminum. Section 201, on solar panels and but also that includes, I would say that also includes anti dumping and countervailing duties. So all of those different types of tariffs and duties that are outside of the normal duty and importing process. So anytime there’s something that’s outside of the norm that’s not a not a normal or more complex process, that’s an area where I get involved. One of the areas, the third area, the third group that I would kind of throw things in, is actually fairly new, and that is de minimis, the under $800 shipments. Right. There have been a lot of companies looking to take advantage of the de minimis. Under $800 section, 321, type, 86 those are all different terms that roughly mean the same thing. That’s a very popular area right now, and it’s an area where not only am I working a lot with companies that are taking advantage of the program, but also working a lot with customs, on the coac and on some of the advisory committees on I’m on, because as the volumes of these low value shipments have skyrocketed. Customs has been struggling to keep up and with and to ensure that trade is done being done properly, even in the de minimis environment. So that’s another area that I’m helping, helping companies out with. Oh,

great. These are awesome areas. What was your favorite project so far on coac?

So I’ve had, actually, I’ve really enjoyed a lot of the projects on coac. I would say that my favorite area that to deal with on coac is the ace 2.0 initiative. So customs, you know, you mentioned earlier that ace, I’m thought of as the ACE person customs, you know, is is in the process of developing the next version of ACE, where customs is looking to build a new to update the platform, to take advantage of more new, modern technology. There’s some terms that you’ll hear. In discussions about the new Ace 2.0 platform, things like interoperability. Interoperability is very important with computer platforms today, in that it allows computers to talk to each other. So, you know, one of the things that I am always amazed with is when I go to my doctor and he needs to refill my prescription, the doctor goes into their doc, the doctor system, and all of a sudden my prescription is at my pharmacy. And if I want to book a flight, I book a flight on the airline’s website, and if I want to book a hotel or an or a or rent a car, it all happens seamlessly. That’s interoperability. And so what customs

is looking to do is to build better interoperability into their new Ace 2.0 platform to allow them to have better ways of communicating with the traders, with the brokers, with the carriers, with all of the different parties, with the government, other government agencies here in the US and abroad, and there are a number of initiatives under this ace 2.0 platform that customs is working on, that is are using new, modern technology. Artificial Intelligence is another one. You’ll also hear about global business identifiers, unique ways of identifying companies that can be shared from party to party, from transaction to transaction, and those are the types of things. And if you ask me, What’s my favorite thing been with with coac, it’s been, it’s been having a front, you know, a front row seat on the discussions about what the new platform is going to

look like, yeah. And then we, we’ve had Vinnie on the show specifically talking about that the interoperability, and I really like the concept and the idea of how customs can help, ultimately, of course, help the consumer identify if that x product, whatever it might Be, a watch or a cap, even, or whatever glasses. I mean, you know, it’s what you thought you bought, you know, like it is really a an Apple watch, and not a knockoff, right? You know, or whatever you know. And I like the way without what’s the word I’m trying to say, without infringing on privacy and and security from the people who are identifying that product. You know what I’m saying? Like, in other words, you don’t have to give away everything. I really like the way they’re doing that, and it sounds like it’s going to move forward a lot, but I did want to say earlier you talked about your work on, for example, textiles and garments, and, you know, the retail business. Before we recorded here, we were talking about your article, the dirt to shirt that you wrote, and how that describes or talks about the process of going through in the sense of supply chain traceability. Let’s just like, summarize it there, right? I mean, and we’ve, we’ve had that initiative, or not initiative, what would you call it? Renee, I mean, that goal here at global Training Center to help companies understand that and why it’s important. So from your article, and from what you wrote on there, I mean, what do you feel like are like the biggest challenges that companies are facing for that right now? I mean, there’s so much involved in that these days. You know what I’m saying. And so I’m just wondering, what do you feel some companies honestly don’t think like it’s a big deal that they don’t even need to comply or even worry about it. I mean, obviously they’re gonna know better here pretty soon. But trade

is an ancient industry, right? You can go back to the days of Christopher Columbus or the Silk Road, and really what was happening then international trade. And if we look at what was happening back hundreds of years ago in the way of international trade, and we compare it to what’s happening today. Over the last few hundreds of years, things have operated very similarly. You know, one of the questions I like to talk about, one of the things I like to talk about is when Christopher Columbus was coming to the Americas, he had on his on the ships, cargo that was looking to be traded or sold. And in addition, he also had a listing of what was on the ship. And we call that listing a manifest. We still have a manifest today. And if we look at global trade, historically, global trade has been about the product at the time it’s traded. And if we look at the regulation of global trade today, and what governments are interested in, or have been interested in until recently, is information about the product at the time the product is cross. The international borders. And the reason that I wrote the blog posts and talked about from dirt to shirt is it was in conjunction with the uflpa, or the Uyghur forced labor Prevention Act, where Customs has been looking at, how can they dive deeper into the life of a product, to understand whether any of the components or raw materials used to make the product were made with forced labor. And if we look at some of the other initiatives that are out there that the governments are looking at, that the government agencies are looking at, whether it be a forced labor issue, free trade agreements, anti dumping, countervailing duties, or even things like environmental aspects. In Europe, they have, they see them, the Carter carbon border adjustment

mechanism, where they’re looking at what is the carbon that was used, that was was created in manufacturing the product, and moving the materials to end the final product. And all of these things have one thing in common, and that is following the data related to making the product, from the time the product is a raw material pulled out of the ground, from dirt, all the way through its life cycle to where the product is exported out of one country, imported into another country. And in some instances, companies and governments are also looking at end of life, right? What happens when the product is recycled or taken to a landfill? And the what we’re going through these, you know, in current times is, in my mind, somewhat of a paradigm shift from the traditional trading of a product and understanding the product at the time that the product is moving across international boundaries, to really having a need To understand a lot more in depth information or data about the product, as from when it becomes starts out as an idea to when the raw materials are gathered and pulled together to make the product. And what we’re seeing is the government is kind of taking the lead and saying, You know what, we need this data to be able to enforce the current laws. But what companies are realizing is that by gathering this data and pulling this data together to be able to satisfy the government requirements, they’re realizing that there’s a lot more value in the data that they can take themselves, and are sometimes looking to see how they can take advantage of that information that they’re getting, because a government agency is asking for it, but now that they have it, they’re looking to see, are there other values that they can get

at? I think the trade is somewhat overwhelmed though. Tom with these new regulations. I mean, the people that I’ve talked to in the committees that I’ve been it’s overwhelming to you know, if you’re not in the retail industry, that is not been your your breath, that’s not what you’ve done. You buy your product from Company A, we don’t know where company a source the raw materials, you know, in general. And so that, I think it tends to be an overwhelming concept while they’re working through it, and especially the high risk sector, sectors, you know, we know those tomatoes and cotton and apparel and poly silicon, those those groups are really being under pressure. You know, to know this. They

absolutely are. And you know, part of the problem is, in many ways, business was easier, right? You if you wanted to make a product, it was easy to source it in one country. You could go to China and they’ll make it for you. Well, companies are now looking to diversify their their sourcing. They no longer want to have all their products made in one country. And so when you import products from multiple countries, or you try to move production from one country to another, you get complications that you’d never had to deal with in the past, right? You may not now, maybe the issue that you’re dealing with is, what are the regulations in some new country to set up a factory, or to export your products, or to get the raw materials into that country to make your products in that other country, and then compound that with things like, let’s say the country that you’re looking at is Mexico, and we have free trade agreement between the US and Mexico and Canada. And so there’s more rules and more things that companies need to do. So you’re absolutely right. Trade has become much more complex, and it’s become more complex for both government regulatory reasons, but also for business reasons that companies want to save money and they want to not have surprises in their

product. Yeah, and I almost feel like they’re the government is using the trade industry to implement. On and enforce a law that’s significantly old. I mean, forced labor law, and, and it’s, it’s a lot on the trade industry to be the sole

it is. And, and, you know, in many situations, companies have given, been given almost impossible tasks. You know, the one that I, the one that I, I think about, is recycled. I don’t know if you know, but clothing recycling no longer happens, or barely happens anymore. Why is that? Because the companies that bought the recycled material can no longer guarantee that no one fiber in their new in their product that was made with recycled material was made with forced labor. So today, customs is looking at doing things like isotope testing, so they might take a pair of jeans and cut out a piece of the fabric and test it. And what happens if one fiber from an old pair of jeans got into that new pair of jeans, and that fiber was made in the Uyghur region of China. That

is so unfortunate. That’s a sad tale. I don’t like that. Tom, you know Adidas, I read this when I was doing my research for forced labor is actually, they’re plastic. They’re getting out of the ocean. They have an initiative. There are a lot of companies

that are doing that. Yeah, I know I was talking with a friend at Honda, who was saying how they have an initiative over the next few years to have every component of their automobiles and their motorcycles and all the other products that they make be 100% recyclable. That’s a that’s a daunting task. But you know what? Consumers are requesting it or demanding it, and companies are starting to step up and listen and say, Yeah, you know what? We don’t want plastics going back into the ocean, and we don’t want trash piles heaping up. We want to be making more intelligent decisions as we’re making products, as we’re buying products, yes,

yeah, that’s, that’s the positive side of it. I agree that’s going to be great when they start making changes in that direction. So you have a amazing career. Tom, I mean, I, I have had the pleasure of working with you, like we said in the beginning, and then I just have, you know, been able to read things about you, and the fact, I mean, you’re like a, your literal pioneer in trade. So thank

you very much. You know, yeah, the industry has been very good to me. The companies have been very good to me and me and my family, and I enjoy it. I really do. I love the people, I love the companies that I work with, and I’m really I’m really glad that I’m back out and having the opportunity to talk to more companies and help more companies to save on duties and not get in trouble while they do so,

yeah, yeah, anybody? Well, we’re going to have your information, right, Lalo and yeah,

so what we’ll do is that we’ll get, we’ll get your more most current information, because I’m sure anybody can do a search on our podcast and find several times, you know what I mean, but we’ll have the most current information there so that they can get in touch. But is there anywhere else that people may see you Tom soon, like at any conferences? Or what are you planning? What is, what is in your near future here?

So I actually have a bunch of things lined up. I’m going to be at the coac meeting in Washington, DC next month. I’m actually going to be in DC for a couple of weeks, because there’s three back to back meetings, both the coac meeting, the national customs broker government affairs conference, that’s where the brokers meet with members of Congress, as well as members out of the administration. And then finally, there’s the trade support network meeting, also in Washington, DC, in October, I’ll be at the westcon, that’s the Western cargo conference for the customs brokers. And then I’ll also be available at, you know, AEI, AAFA, other conferences, out and about, and companies can always reach me via email. I’m actually starting to work on a website. So I’ll have a website up and up in probably in a month or two, but I’ll send that information over to you when I get that up and running.

Sure, yeah, we can always update the show notes. So just keep checking the show notes. And when you see a website, that means it’s up and running for Tom. So that’s, that’s, that’s the magic of technology. We can actually update all that, all that information. So interesting. So yeah, so we’ll run into you and into some of these events, and then well into 2025, depending on what that brings for you as well. And you know, looking forward to tapping some of your knowledge as well. Here internally for global Training Center in one way or another, but, but really looking forward to collaborating maybe more with you, and I’m glad we, we connected again here for this version of the podcast, and really glad that you we were able to do this and and get this out so Renee, anything else or I

have one more thing to say that Tom is the father of dirt to shirt. I didn’t know that. I think everybody should know and be careful don’t get a hold of Tom Gould, the executive producer of love Island, when you want customs trading. No, Tom, it’s a pleasure. We’re really grateful to talk to you. My

pleasure, too. Thank you very much.