The BOC Blast 314 – Turkey Terminated from Generalized System of Preferences

Turkey Eliminated from Generalized System of Preferences (GSP)

 

The Federal Register has published the official notification that the designation of Turkey as a beneficiary developing country is terminated, effective May 17, 2019.

Please see the link, below, and the attached PDF for the full language.

 

The BOC Blast 314 5-21-2019 Turkey Terminated from Generalized System of Preferences – GSP Federal Register PDF

 

https://www.federalregister.gov/documents/2019/05/21/2019-10761/to-modify-the-list-of-beneficiary-developing-countries-under-the-trade-act-of-1974

 

The BOC Blast 313 – List 4 Proposed Tariffs Published

List 4 Proposed Tariffs Published

 

On May 13, 2019 the USTR proposed a 25% tariff on a fourth listing of products. This listing, estimated at $300 billion in trade value, will cover almost all remaining import products from China including textiles, shoes, and many of the “other” classifications that had not been included previously.

 

The due date for written comments is June 17th, with public hearings scheduled for the same day. There is no proposed effective date for the new tariffs in the publication.

 

Please go to the following link for full Office of the US Trade Rep posting:

https://ustr.gov/sites/default/files/enforcement/301Investigations/May_2019_Proposed_Modification.pdf

The BOC Blast 312 – British Columbia longshore workers move closer to strike

British Columbia longshore workers move closer to strike

Nate Tabak, Canada Correspondent  | www.freightwaves.com

 

ILWU members vote to authorize walk-outs “if necessary,” threatening to disrupt operations at Canada’s largest port, Vancouver.

 

The Port of Vancouver handles the largest volume of cargo in Canada. Photo: Vancouver Fraser Port Authority/Colin Jewell Photography

 

Longshore workers in British Columbia overwhelmingly voted to authorize a strike, raising the specter of a disruption at the Port of Vancouver, Canada’s busiest port.

 

The International Longshore and Warehouse Union (ILWU) Canada announced on May 10 that 98.4 percent of local members voted “in favor of supporting strike action if necessary.” A work stoppage could come at any time during the next 60 days, with 72 hours notice.

 

It significantly raises the stakes in contract negotiations between ILWU Canada and the British Columbia Maritime Employers’ Association (BCMEA), which represents companies operating at the ports. A contract for the longshore workers expired in March 2018.

 

The ILWU and the BCMEA agreed on their previous contract in 2010 after the longshoremen authorized a strike.

 

About 2,700 ILWU longshoremen work at British Columbia’s ports, which handled 3.6 million 20-foot-equivalent units (TEUs) of cargo in 2018. Most went to Vancouver, whose volumes hit a record 3.4 million TEUs and 147 million metric tons in 2018.

 

A federal mediator has been attempting to bring get the two sides to reach an agreement. Neither the union or BCMEA has disclosed their areas of contention.

 

The average unionized longshore worker earned about C$119,000 per year in 2018 (a Canadian dollar equals US$0.75), according to the BCMEA. Their pay lags behind longshore workers at major U.S. ports on the West Coast, who earned about US$171,000 per year on average in 2018, according to the Pacific Maritime Association.

 

About C$200 billion in trade goes through the Port of Vancouver each year, and it serves as Canada’s main gateway for Asia.

 

The Canadian International Freight Forwarders Association warned in April that a strike would hurt Canada’s supply chain, and could result in cargo permanently being redirected to ports in the U.S.

 

Nate Tabak, Canada Correspondent

 

Nate Tabak is a journalist, editor and producer in Toronto. He covers Canada for FreightWaves, with a keen interest on the cross-border economic relationship with the United States. Nate spent seven years working as an investigative editor and reporter based in Kosovo. He covered everything from corruption to the country’s emerging wine industry. He also reported across the Balkans and investigated Albania’s multibillion-dollar marijuana industry with a grant from the Pulitzer Center on Crisis Reporting. Nate grew up in Berkeley, Calif. He enjoys exploring Toronto with his wife and is always looking forward to his next meal.

 

The BOC Blast 311 – Implementing Modification to Section 301 Action

 

[Billing Code 3290-F9]

 

OFFICE OF THE UNITED STATES TRADE REPRESENTATIVE

 

Implementing Modification to Section 301 Action: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation

 

AGENCY: Office of the United States Trade Representative.

 

ACTION: Notice of implementing modification.

 

 

SUMMARY: In a notice published on May 9, 2019 (May 9 Notice), the U.S. Trade Representative (Trade Representative) increased the rate of additional duty from 10 percent to 25 percent for the products of China covered by the September 2018 action that are (i) entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on May 10, 2019, and (ii) exported to the United States on or after May 10, 2019. This notice provides that products of China that are covered by the September 2018 action and that were exported to the United States prior to May 10, 2019, are not subject to the additional duty of 25 percent, as long as such products are entered into the United States prior to June 1, 2019. Such products remain subject to the additional duty of 10 percent for this interim period.

 

DATES: HTSUS heading 9903.88.09, which is set out in the Annex to this notice, applies to products of China covered by the September 2018 action that were exported before May 10, 2019, and entered into the United States on or after May 10, 2019, and before June 1, 2019.

 

FOR FURTHER INFORMATION CONTACT: For questions about this notice, contact Associate General Counsel Arthur Tsao or Assistant General Counsel Juli Schwartz, or Director of Industrial Goods Justin Hoffmann at (202) 395-5725. For questions on customs classification or implementation of additional duties on products covered in the supplemental action, contact traderemedy@cbp.dhs.gov.

 

SUPPLEMENTARY INFORMATION:

 

In the May 9 Notice, the Trade Representative modified the action being taken in the Section 301 investigation by increasing the rate of additional duty from 10 percent to 25 percent for the products of China covered by the September 2018 action in this investigation. The “September 2018 action” refers to the additional duties on products of China with an annual trade value of approximately $200 billion, published at 83 FR 47974 (Sep. 21, 2018), as subsequently modified by the notice published at 83 FR 49153 (September 28, 2018). The increase in the rate of additional duty became effective on May 10, 2019.

 

Under this implementing modification, and as specified in the Annex to this notice, products of China that are covered by the September 2018 action that were exported prior to May 10, 2019, are not subject to the additional duty of 25 percent as long as such products are entered into the United States prior to June 1, 2019. Such products remain subject to the additional duty of 10 percent for a transitional period of time before June 1, 2019. The covered products of China that are entered into the United States on or after June 1, 2019, are subject to the 25 percent rate of additional duty.

 

To distinguish between covered products of China subject to the 10 percent rate of additional duty from those subject to the 25 percent rate, the Annex to this notice creates a new heading in Chapter 99 of the HTSUS (9903.88.09) for products of China covered by the September 2018 action that were exported before May 10, 2019, and entered into the United States on or after May 10, 2019 and before June 1, 2019. HTSUS heading 9903.88.09 is limited to covered products of China entered into the United States during this period of time to account for customs enforcement factors and the average transit time between China and the United States by sea.

 

The products of China covered by the September 2018 action that are admitted into a foreign-trade zone (FTZ) in “Privileged Foreign” status shall retain that status consistent with 19 CFR 146.41(e) and will be subject, at the time of entry for consumption, to the additional duty rate that was in effect at the time of FTZ admission of said product.

 

U.S. Customs and Border Protection will issue instructions on entry guidance and implementation.

 

 

Joseph Barloon

General Counsel

Office of the U.S. Trade Representative.

 

 

 

ANNEX

 

 

Effective with respect to goods: (1) exported to the United States before May 10, 2019; and (2) entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on May 10, 2019, and entered for consumption, or withdrawn from warehouse for consumption, before 12:01 a.m. eastern daylight time on June 1, 2019, subchapter III of chapter 99 of the Harmonized Tariff Schedule of the United States (HTSUS) is modified:

 

 

  1. by inserting the following new heading 9903.88.09 in numerical sequence, with the material in the new heading inserted in the columns of the HTSUS labeled “Heading/Subheading”, “Article Description”, and “Rates of Duty 1-General”, respectively:

 

 

Heading/ Subheading  

Article Description

Rates of Duty
1 2
General Special
“9903.88.09 Articles the product of China, as provided for in U.S. note 20(l) to this subchapter and as provided for in the subheadings enumerated in U.S. notes 20(f) or 20(g) to this subchapter, if exported to the United States before May 10, 2019 and entered for consumption, or withdrawn from warehouse for consumption, on or after May 10, 2019, and before June 1, 2019 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  

 

 

 

 

 

 

 

The duty provided in the applicable subheading

+ 10%”

   

 

 

 

  1. by inserting the following new U.S. note 20(l) to subchapter III of chapter 99 in numerical sequence:

 

“(l) For the purposes of heading 9903.88.09, products of China, as provided for in this note, shall be subject to an additional 10 percent ad valorem rate of duty. The products of China that are subject to an additional 10 percent ad valorem rate of duty under heading 9903.88.09 are products of China that are classified in the subheadings enumerated in U.S. notes 20(f) or 20(g) to subchapter III. All products of China that are classified in the subheadings enumerated in U.S. notes 20(f) or 20(g) to subchapter III are subject to the additional 10 percent ad valorem rate of duty imposed by heading 9903.88.09.

 

For the purposes of heading 9903.88.09, the products of China that are subject to an additional 10 percent ad valorem rate of duty are products that are: (1) exported to the United States before May 10, 2019; and (2) entered for consumption, or withdrawn from warehouse for consumption on or after May 10, 2019, and before June 1, 2019.

 

Notwithstanding U.S. note 1 to this subchapter, all products of China that are subject to the additional 10 percent ad valorem rate of duty imposed by heading 9903.88.09 shall also be subject to the general rates of duty imposed on products of China classified in the subheadings enumerated in U.S. notes 20(f) or 20(g) to subchapter III.

 

Products of China that are classified in the subheadings enumerated in U.S. note 20(f) or 20(g) to subchapter III and that are eligible for special tariff treatment under general note 3(c)(i) to the tariff schedule, or that are eligible for temporary duty exemptions or reductions under subchapter II to chapter 99, shall be subject to the additional 10 percent ad valorem rate of duty imposed by heading 9903.88.09.

 

The additional duties imposed by heading 9903.88.09 do not apply to goods for which entry is properly claimed under a provision of chapter 98 of the HTSUS, except for goods entered under subheadings 9802.00.40, 9802.00.50, and 9802.00.60, and heading 9802.00.80. For subheadings 9802.00.40, 9802.00.50, and 9802.00.60, the additional duties apply to the value of repairs, alterations, or processing performed abroad, as described in the applicable subheading. For heading 9802.00.80, the additional duties apply to the value of the article less the cost or value of such products of the United States, as described in heading 9802.00.80.

 

Products of China that are provided for in heading 9903.88.09 and classified in one of the subheadings enumerated in U.S. notes 20(f) or 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees, exactions and charges that apply to such products, as well as to the additional 10 percent ad valorem rate of duty imposed by heading 9903.88.09.”

 

The BOC Blast 310 – 25 % on List 3 Pre publication Federal Notice

This document is scheduled to be published in the Federal Register on 05/09/2019 and available online at https://federalregister.gov/d/2019-09681, and on govinfo.gov

  

OFFICE OF THE UNITED STATES TRADE REPRESENTATIVE

 

Notice of Modification of Section 301 Action: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation

 

AGENCY: Office of the United States Trade Representative.

 

ACTION: Notice of modification of action.

 

 

SUMMARY: In accordance with the direction of the President, the U.S. Trade Representative (Trade Representative) has determined to modify the action being taken in this Section 301 investigation by increasing the rate of additional duty from 10 percent to 25 percent for the products of China covered by the September 2018 action in this investigation. The Trade Representative has further determined to establish a process by which interested persons may request that particular products classified within a tariff subheading covered by the September 2018 action be excluded from the additional

duties.

 

DATES: The rate of additional duty will increase to 25 percent with respect to products covered by the September 2018 action on May 10, 2019.

 

FOR FURTHER INFORMATION CONTACT: For questions about this notice, contact Associate General Counsel Arthur Tsao, Assistant General Counsel Philip Butler, or Director of Industrial Goods Justin Hoffmann at (202) 395–5725. For questions on customs classification or implementation of additional duties on products covered by the September 2018 action, contact traderemedy@cbp.dhs.gov.

 

SUPPLEMENTARY INFORMATION:

 

  1. September 2018 Action

 

For background on the proceedings in this investigation, please see the prior notices issued in the investigation, including 82 FR 40213 (August 23, 2017), 83 FR 14906 (April 6, 2018), 83 FR 28710 (June 20, 2018), 83 FR 33608 (July 17, 2018), 83 FR 38760 (August 7, 2018), and 83 FR 40823 (August 16, 2018).

 

In a notice published on September 21, 2018 (83 FR 47974), the Trade Representative, at the direction of the President, announced a determination to modify the action being taken in the investigation by imposing additional duties on products of China with an annual trade value of approximately $200 billion. The rate of additional duty initially was 10 percent. Those additional duties were effective starting on September 24, 2018, and currently are in effect. Under Annex B of the September 21 notice, the rate of additional duty was set to increase to 25 percent on January 1, 2019. In the September 21 notice, the Trade Representative stated that he would continue to consider the actions taken in this investigation, and if further modifications were appropriate, he would take into account the extensive public comments and testimony previously provided in response to the notices published on July 17, 2018 (83 FR 33608) and August 7, 2018 (83 FR 38760).

 

On September 28, 2018 (83 FR 49153), the Trade Representative issued a conforming amendment and modification of the September 21 notice. The current notice refers to the September 21 notice, as modified by the September 28 notice, as the ‘September 2018 action.’

 

On December 19, 2018 (83 FR 65198), in accordance with the direction of the President, the Trade Representative determined to modify the September 2018 action by postponing until March 2, 2019, the increase in the rate of additional duty to 25 percent.

 

The Annex to the December 19 notice, which superseded Annex B to the September 21 notice, amended the Harmonized Tariff Schedule of the United States (HTSUS) to reflect this postponement of the increase in the rate of duty applicable to the September 2018 action.

 

On March 5, 2019 (84 FR 7699), in accordance with the direction of the President, the Trade Representative determined to modify the September 2018 action by postponing until further notice the increase in the rate of additional duty to 25 percent.

 

Annex B of the September 21 notice (83 FR 47974) and the Annex to the December 19 notice (83 FR 65198) were rescinded. In accordance with Annex A of the September 21 notice, the rate of additional duty under the September 2018 action remained at 10 percent until further notice.

 

  1. Determination to Further Modify September 2018 Action

 

The United States is engaging with China with the goal of obtaining the elimination of the acts, policies, and practices covered in the investigation. The leaders of the United States and China met on December 1, 2018, and agreed to hold negotiations on a range of issues, including those covered in this Section 301 investigation.

See https://www.whitehouse.gov/briefings-statements/statement-press-secretary-regarding- presidents-working-dinner-china/. Since the meeting on December 1, the United States and China have engaged in additional rounds of negotiation on these issues, including meetings in March, April, and May of 2019. In the most recent negotiations, China has chosen to retreat from specific commitments agreed to in earlier rounds. In light of the lack of progress in discussions with China, the President has directed the Trade Representative to increase the rate of additional duty to 25 percent.

 

Section 301(b) of the Trade Act of 1974, as amended (Trade Act), provides that the Trade Representative “shall take all appropriate and feasible action authorized under [Section 301(c)] to obtain the elimination of [the] act, policy, or practice [under investigation].” Section 307(a)(1) of the Trade Act authorizes the Trade Representative to modify or terminate any action being taken under Section 301, subject to the specific direction, if any, of the President if “the burden or restriction on United States commerce . . . of the acts, policies, and practices, that are the subject of such action has increased or decreased, or such action is being taken under Section [301(b)] of this title and is no longer appropriate.” In light of the lack of progress in the additional rounds of negotiations since March 2019, and at the direction of the President, the Trade Representative has determined that it is appropriate for the rate of additional duty under the September 2018 action to increase to 25 percent on May 10, 2019.

 

The Trade Representative’s decision to modify the September 2018 action takes into account the extensive public comments and testimony, as well as advice from advisory committees, concerning the actions proposed in the notices issued in advance of the September 2018 action (83 FR 33608 and 83 FR 38760). Those notices, among other things, requested comments on whether the rate of additional duties should be 10 percent or 25 percent. The Trade Representative’s decision also reflects the advice of the interagency Section 301 Committee.

 

The Annex to this notice amends the Harmonized Tariff Schedule of the United States to provide that the rate of additional duties for the September 2018 action will increase to 25 percent on May 10, 2019.

 

Pursuant to Sections 301(b), 301(c), 304(a), and 307(a) of the Trade Act, the Trade Representative has determined that the Office of the United States Trade Representative (USTR) will establish a process by which interested persons may request that particular products classified within an HTSUS subheading covered by the September 2018 action be excluded from the additional duties. USTR will publish a separate notice describing the product exclusion process, including the procedures for submitting exclusion requests, and an opportunity for interested persons to submit oppositions to a request.

 

ANNEX

 

Effective with respect to goods (i) entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. eastern daylight time on May 10, 2019, and (ii) exported to the United States on or after May 10, 2019, subchapter III of chapter 99 of the Harmonized Tariff Schedule of the United States is modified:

 

  1. by amending U.S. Note 20(e) to subchapter III of chapter 99 by deleting “10 percent” each place that it appears, and inserting “25 percent” in lieu thereof;

 

  1. by amending U.S. Note 20(g) to subchapter III of chapter 99 by deleting “10 percent” each place that it appears, and inserting “25 percent” in lieu thereof;

 

  1. by amending the Rates of Duty 1-General column of heading 9903.88.03 by deleting “10%”, and inserting “25%” in lieu thereof; and

 

  1. by amending the Rates of Duty 1-General column of heading 9903.88.04 by deleting “10%”, and inserting “25%” in lieu thereof.

 

Joseph Barloon

General Counsel

Office of the U.S. Trade Representative.

The BOC Blast 309 – China Tariffs to Increase

Certain China Duties to Increase Friday May 10, 2019

 

Although nothing official has been issued by the government, President Trump announced yesterday that effective Friday, May 10, the tariffs for products covered by List 3 of the Section 301 program will increase from 10% to 25%.  This is a result of what appears to be stalled negotiation talks with China, although it appears that the Chinese delegation will come to Washington for continued talks this week.

 

In addition, he has threatened to impose the 25% tariffs on all products from China.

 

As many may recall, these duties were to be implemented in March.  However, President Trump issued an executive order stating that implementation was delayed until further notice.  The two countries have been working on a trade agreement to address China’s unfair trade practices.

 

Additionally, last Friday US Trade Representative Lighthizer announced that his office is in the process of establishing an exclusion process for goods on List 3.  According to his statement, the office hopes to have the process in place by the end of May. It appears at this time the process will be allowed for the products whether or not the tariffs increase to 25%.

 

Potential options for avoiding or reducing the increased tariff, include the following:

  1. Tariff Classification – although many companies have reviewed this with the previous two lists, verifying the classification should still be considered as a potential option.
  2. Country of origin – companies should look closely at the supply chain. It may be time to consider sourcing products elsewhere.  However, careful consideration should be given to making moves to a third country, particularly if your China supplier is involved and/or there would be China content included in the product.  Companies need to ensure that the product is being substantially transformed in the third party country.
  3. Use of Chapter 98 provisions, duty drawback, bonded warehouses and Foreign Trade Zones also provide options in certain situations, particularly if products will be later exported from the U.S.
  4. Value strategies – companies can consider legitimate means of lowering the transaction value. Options include potential discounts, and use of the “first sale” rule if there is a multi-tiered transaction involving a middleman.
  5. Exclusion Requests – Exclusion requests may be granted when a company can substantiate to the government that the product in question cannot be sourced in the U.S. or third party countries, there would be severe economic hardship to the requestor or other US interests and the product is not part of the “Made in China 2025” or other industrial programs.

 

It appears that talks between the two countries scheduled for this Wednesday will continue and hopefully the announced increase will not take place.

If you have questions, please contact your BOC Representative, or Paula Connelly, Esq.

 

Information for this BOC Blast provided by The Law Offices of Paula M. Connelly

The BOC Blast 308 – Proposed List of EU Products – Retaliatory Duties

Proposed List of EU Products – Retaliatory Duties

 

As you may know, the U.S. has issued a list of proposed EU products that may be subject to retaliatory duties as a result of a World Trade Organization decision in which it was determined that the U.S. was harmed by subsidies granted by the EU and certain member States to the EU large civil aircraft domestic industry, on the basis that the subsidies appeared to be inconsistent with their obligations under the General Agreement on Tariffs and Trade 1994 (GATT 1994) and the Agreement on Subsidies and Countervailing Measures
(SCM Agreement).

 

In order to enforce U.S. WTO rights in connection with the Large Civil Aircraft dispute, the Trade Representative is initiating a section 301 investigation of the subsidies provided by the EU and certain member States on the manufacture of large civil aircraft.

 

According to the Federal Register Notice, “upon determining that U.S. rights under a trade agreement are being denied, section 301(a) provides that the Trade Representative shall take all appropriate and feasible action authorized under section 301(c), subject to the specific direction, if any, of the President regarding such action, and all other appropriate and feasible action within the power of the President that the President may direct the Trade Representative to take to enforce such rights. Pursuant to sections 301(a), 301(c), 304(a)(1)(B), and 306(b)(2), the Trade Representative proposes that appropriate action would include the imposition of additional ad valorem duties of up to 100 percent on products of the EU or certain member States, to be drawn from the preliminary list of HTS numbers in the attached Annex.”

 

As you may know, the China tariffs currently in affect, were also initiated as a result of a Section 301 investigation by the U.S. Trade Representative’s office.

 

Please note that the U.S. government may impose additional duties of up to 100% on the final list of products.

 

This is the not the first time the U.S. government has initiated retaliatory duties against EU products.  The U.S. and EU were involved in a long-standing dispute over the EU’s ban of U.S. beef from cattle treated with hormones.  In 1999, retaliatory duties of 100% were assessed on a substantial number of EU products.  These duties were in place until May 2009 when the U.S. and EU signed a Memorandum of Agreement.

 

However, it appears that the U.S. and EU may be entering into negotiations for a potential trade agreement.   It remains to be seen how this may affect the current proposal for retaliatory duties.

 

There will be a public hearing in Washington D.C. on May 15 to discuss the proposal and comments may be submitted to the USTR’s office through May 28.

 

I will keep you posted of any developments.

 

Sincerely,

Paula Connelly

Enc.

The BOC Blast 306 – Delays ex Qingdao

  

Delays Expected ex-Qingdao Port in April

 

Due to the celebration of the 70th Anniversary of the People’s Liberation Army of Navy in China, a large-scale naval battleship event will be held on April 23rd, in Qingdao, China.

 

Controls will be implemented over inland and ocean transportation from April 20th – 23rd. There also will be a suspension of DG (Dangerous Goods) cargo operations for DG classes 1 – 7, from April 15th to April 30th.

 

Please expect delays to cargo delivery and vessel departure from Qingdao port.

 

Chinese navy’s 70th birthday parade set to showcase country’s rising sea power

Nautical spectacle will allow country to show off its most advanced warships to an international audience.

More than a dozen foreign navies are expected to join in, including the United States.

(Excerpted from South China Morning Post)

The BOC Blast 305 – 4th Annual St Patricks Day Innovation Supply Chain Summit

2019 BOC’S ANNUAL INNOVATIVE ST. PATRICK’S DAY SUMMIT

We want to thank all that were able to attend our 4th Annual St. Patrick’s Day Innovation Supply Chain Summit and share some information with those of you that unfortunately were unable to attend. This year we had several informative speakers that drove discussion and interaction from everyone in attendance. Following the speaker sessions that we had in the morning, and some entertainment at lunch, we closed the day with a roundtable discussion with several industry experts. We are fortunate that the presenters have allowed us to share their presentation. Please use the link below to access the presentation.

Click here to access presentation

http://www.bocintl.com/en/wp-content/uploads/2019/04/31519-Master-Presentation.v3.pdf

We are looking forward to holding next year’s event on March 13th, 2020. In addition to our annual St. Patrick’s Day Innovation Supply Chain Summit we hold several other events throughout the year in Boston Innovation Seaport District at our Global Headquarters. These events include Port Tours, Trade Day with US Customs and several other training sessions to help inform our clients. If you have any interest in attending these events or gaining more information, please reach out to your BOC representative or BOCEvents@bocintl.com