Questions and answers about Export


    QUESTION: Is anyone aware of a license exception that would allow a US company to export ENC Restricted encryption products to government end-users? If so, what is the license exception reference number. I do not see such an exception in 740.17. ************* Answers: That’s the point, it’s restricted to NON government end-users. You will need […]

  • Missed EEI filing

    QUESTION: One of our locations could not complete the EEI filing because the system went down. The product was shipped anyway with an EEI filing. Value of $3,500.00. How do we fix this? Do we self report? To whom? Will there be fines or penalties? =========== Answers: File it today. Don’t wait. Your forwarder or […]


    QUESTION: We had a collect shipment valued at $ 75,000 and our customer assigned the U.S. forwarder. In the case of collect shipments, we required the foreign customer to complete a FPPI Routed Export Form which transfers all export responsibility from us, the USPPI , to the foreign customer and their U.S. Agent/ freight forwarder […]


    QUESTION: Our non-US distributor, to received favorable treatment on their non-US govt tender, wants a US export of a breakdown our machinery into about 10 components, so the distributor creates assembly jobs in their country. Assuming no spare parts, for the US export and EEI filing, can the US invoice/EEI filing be under the one […]

  • Exporting Sample

    QUESTION: My company is shipping a sample of a hardware product that has not launched yet. It’s still under development and not final product. Can I classify it as ECCN as EAR99 or not classify? This is a small item that can ship via Couriers. Is there a special Schedule B number that I can […]

  • Customer Drop Ship USPPI

    QUESTION: Can anyone share a practical method for EEI responsibility handling on courier drop ships, where the seller of the goods is paid by a US customer but is requested to ship to another country via courier on behalf of the US buyer? ********************** Answers: Assuming that you are the U.S. domestic seller, your U.S. […]

  • Do Export Violations go away, expire, get expunged?

    QUESTION: One of the companies we are considering to conduct business with had a BIS administrative proceeding opened up against it back in 2007. There was an official investigation and “Charging letter”. Company agreed with findings and paid fines etc. Any issues with working with this company now? That happened in 2007. It’s 2019. Do […]


    QUESTION: Our Mexican entity, subsidiary of our company headquartered in the U.S., will be receiving shipment from Canadian suppliers. The shipments will first be imported and entered into the U.S. where they will be consolidated. The shipment will be imported under the Mexican entity under their foreign Imported of Record number. The shipment will then […]


    QUESTION: I have an item that came back from Mexico customer for repair in the US covered under warranty. Now repair is done and we are ready to ship it out. This item falls under Heading 8473. When I ship out their repair unit, do I use the same Heading 8473 or is there a […]


    QUESTION: Are there regulations that I can cite when explaining why we need to use the correct value of goods when we export products? ******************* Answers: FTR §30.1 Export Value: The selling price (or the cost if the goods are not sold) in U.S. dollars, plus inland or domestic freight, insurance, and other charges to […]

  • Exporter Company Name Changed after PO Issued

    QUESTION: We have a related party in Taiwan that exports to our US organization. We issued POs to their original name. They legally changed their name after the POs were issued. The commercial invoice, packing list, and Sea Waybill were issued under the new name. Does this present any issued for a Customs audit – […]


    QUESTION: I am hoping the community can help me on the specific question of transactions due diligence for products shipping to Ukraine. US have sanctions over Russia and Crimea Region. As I understand, Crimea is annexed by Russia and “de facto” Russian territory Products shipped to Ukraine cannot ship to Crimea as it is a […]