• USA Employee and NRI

    QUESTION: I have been seeing questions regarding a USA employee working for a USA employer and asking if they could perform “customs business” for subsidiaries, …etc. Also read regarding a USA employee working for that USA employer that is a subsidiary of a holding company in a foreign country, and that holding company is also […]

  • Multi-purpose use goods, T.D. 89-80, 54 Fed. Reg. 35127 (8/23/89), Principle Use Provision, E.M. Chem, icals v USA 20 C.I.T. 382, 923, F. Supp. 202 (1996 Ct Intl Trade)

    QUESTION: Can anyone direct me to more information that explains the concept of “principle use provisions”. Can you share electronic versions of the following? • T.D. 89-80, 54 Fed. Reg. 35127 (8/23/89) • E.M. Chemicals v USA 20 C.I.T. 382, 923, F. Supp. 202 (1996 Ct Intl Trade) • Group Italglass U.S.A., Inc. v. United […]

  • Non US personnel managing US imports

    QUESTION: Does anyone have any feedback in the membership as it relates to non-US employees managing imports into the U.S.? Is there concern over allowing them to access the data that will be transmitted to US customs? Is there a section in the regulations that addresses this matter? ************* Answers: It’s perfectly fine. There is […]

  • Imports from China with USA content

    QUESTION: Regarding tariffs and duties: Lithium batteries and cells imported from China from our a wholly owned subsidiary, are produced, in part, using materials that are provided from our plant in the USA. The materials that are shipped from our USA plant to China are made and sourced in the USA. I don’t have an […]

  • Structure – HS Classification organization

    QUESTION: I am looking for data regarding how companies structure their organization for personnel that are responsible for HS classification determination. I am particularly interested in large companies classifying chemical or other commodities that require specialized technical skills (for example: a chemist) for classification. Is it centralized under one department? Is it centralized under one […]


    QUESTION: Has anyone from the membership successfully argued and eliminated the duty/fee liability where goods were seized because of an OGA requirement not met and not entered into U.S. commerce as a result? If so, what regulation/guidance was relied on in presenting to CBP. Thank you for your time in advance! **************** Answers: Not sure […]


    QUESTION: What is the benefit to have a CBP national account manager? What size of company is good to have one. We are in the CTPAT program, we have a custom assigned agent look after our CTPAT, is this person also our national account manager. What are some disadvantages to have CBP national account manager? […]


    QUESTION: We are a pharmaceutical company recently expanded. We hope to implement a single global standard on determining country of origin. We do not take advantage of FTA’s as they do not financially benefit us. Any thoughts on the possibility of implementing one global process applicable in more than 50 countries? Would it be advisable […]

  • Exclusion requests application cell data integrity

    QUESTION: Is anyone else in the steel industry or trade community having a problem when filling out the exclusion request with the excel cell rounding their entered data? Example- in the cell for minimum thickness, I type 3.68mm but the exclusion request application rounds it to 4mm automatically. This is not what I typed but […]

  • Misrouted Shipment Guidance

    QUESTION: Cast of Characters • Company DE • Company KR • Company U.S. • Forwarder DE • Forwarder U.S. • Broker U.S. • Pallet A-U.S. • Pallet B-U.S. • Pallet C-KR Scene (Problem) • Company DE exported Pallets A-U.S. and Pallet C-KR, to U.S. (EXW) • Company DE exported Pallet B-U.S. to KR (EXW) Notes […]


    QUESTION: Is it compliant under the OFAC sanctions for a U.S. company, to sell a U.S. product to CITGO for delivery to CITGO in the U.S.? %%%%%%%%%%% ANSWER At the moment, the US has exempted Citgo from its sanctions until July 27. Still, I would recommend flagging as a high-risk customer already now, as these […]


    QUESTION: Who does the BAA compliance analysis at your company? I feel like it should be procurement or supply chain. I’m a trade compliance manager and I’m being asked to do it. I feel like it shouldn’t be me. Am I wrong? ********************* Answers: From a procurement standpoint there really is not much for either […]