Miscellaneous

MISCELLANEOUS

  • IMMEX risk assessment questions

    QUESTION: I am preparing a compliance audit/ risk assessment for my facility in Mexico. In addition to topics such as classification, valuation, etc., what questions should I ask specifically for IMMEX compliance? ========== Answers: Valuation method declared upon import and upon export usually the raw material imported is under consigment so no direct sale, but […]

  • Why/when use outside counsel?

    QUESTION: I know this is a broad question, but when do members use outside counsel for trade compliance matters? (Some areas that come to mind include expertise lacking in-house, experience dealing with the government, benchmarking to others in your industry, or more resources/bandwidth). Thanks! ========== Answers: Really, this depends on how far your internal expertise […]

  • EIN suffixes

    QUESTION: My company has a corporate EIN and several divisions with their own EIN’s. Each division’s shipments have been imported under the corporate name and EIN. Is that OK? If not, please explain why not. Now we want to add suffixes to the corporate EIN so we can distinguish each division’s data when we run […]

  • German Customs Recordkeeping requirements

    QUESTION: Can anyone tell me the specific German/EU customs code citations for recordkeeping and the types of records that need to be kept for German Customs imports? For example, i the US, recordkeeping requirements are spelled out in 19 CFR PArt 163 and Appendix (a)(1)(A) List. ANSWERS: https://www.gesetze-im-internet.de/hgb/__257.html

  • Number of HS Codes

    QUESTION: I’ve read that in the 98 Chapters of the US HTS there are 5,000 headings and subheadings. Does anyone know, approximately, how many 10 digit US HS Codes there are? %%%%%%%%%% ANSWERS: 11k You can download the excel @ https://hts.usitc.gov/export %%%%%%%%%% Based on my most recent extract (this includes the 8 digit complete codes […]

  • BENEFICIAL OWNERSHIP

    QUESTION: In screening for restricted parties in the sanctions realm, we know that it is necessary to look not only whether the transaction entity itself is restricted, but whether it is 50% or more owned by one or more restricted parties. That is, “ownership” must be determined? Why do I sometimes see people refer to […]

  • MTB PETITIONING

    QUESTION: We import a plastic sheathing from China with a duty rate of 5.3% ad valorem and 301 tariff of 25%. We are looking to file a MTB petition for a duty reduction as the quantity we import is quite high but will not be over the $500,000 loss of revenue cap. We use the […]

  • COMPLIANCE SUBCONTRACTING

    QUESTION: I currently work in the automotive industry. I am the only person responsible for all international trade and compliance for our plant in Ohio. Recently we were obtained and I have been thinking about going out on my own. I already have a Bachelor’s in Business and am a Certified Classification Specialist. Besides getting […]

  • SANCTION VS EMBARGO COUNTRIES

    QUESTION: 1) What is the difference between sanction and embargo countries? 2) What is the difference on sanction/embargo countries on the BIS and OFAC list? **************** Answers: Trade sanctions target specific types of transactions, as in a prohibition to sell arms to a specific business, country, government or regime. An embargo represents a complete prohibition […]

  • Goods Sold In Transit Requirements

    QUESTION: We are looking for input regarding a Goods Sold in Transit scenario. We are a US based company and purchase or transfer not controlled items from suppliers and subsidiaries within the EU to other subsidiaries outside the EU. As well as shipments between different countries or customs regions outside of the EU. The transfer […]

  • Rosneft in Vietnam

    QUESTION: Provided it complies with the Directives (no Arctic, shale, etc), can a US company do business with Rosneft Vietnam? Could a UK company? I think the answer is yes, so long as we’re careful about end use and location. *************** Answers: Rosneft is listed under three major restrictions: 1. BIS Entity List 2. OFAC […]

  • Vetting Form or Template for Foreign Supplier

    QUESTION: We are importing goods and would like to know if there is a specific vetting form or template when selecting foreign suppliers? If not, does anyone have one they don’t mind sharing? *************** Answers: This is more of a sourcing or procurement role and QA supplier qualification role. Trade Compliance does have a “part […]