Miscellaneous

MISCELLANEOUS

  • SIGNATURE FOR END USER FORMS,,

    QUESTION: Currently we send our customers End User Forms that have to  filled out and signed manually. On this form we ask our customers to certify the product(s) they are purchasing will not be put to any prohibited end use or exported to an embargoed country and request the customer manually sign the form and […]

  • ANTI-BOYCOTT LANGUAGE EXAMPLE

    QUESTION: We discovered prohibited language in a L/C from our customer in Pakistan. Shipment in Israeli Flag Vessel Is Not Allowed We informed the customer this language had to be removed before we could proceed with the shipment, customer sent back a revised L/C removing the language but replacing with:         Shipment and Transhipment should […]

  • Mailing address for customs correspondence

    QUESTION: Our compliance department is not located at corporate and we would like to know if it’s possible to change the mailing address for customs correspondence to the offsite address without changing the IOR location at corporate.  I talked to our broker and they said this was not possible unless the IOR address was changed […]

  • What licensing vehicle to use in SNAP-5 TMP to in country transfer

    QUESTION: Our company sent hardware to our foreign subsidiary in for use in a trade show.  Now our foreign subsidiary would like to do an in country transfer to another company. Based on the ECCN and the BIS Part 740.9 the article sent to our foreign subsidiary qualified for the BIS TMP exception.  Since the first […]

  • Licensing agreements

    QUESTION: We are wondering if anyone in the membership can provide a clear answer to a question we have about when a licensing agreement should be counted as an assist. Here is the scenario: Company A is an importer in the US and pays for a license to use Company B’s (which is also located […]

  • Origin and export compliance

    QUESTION: When filing the EEI, indicating domestic or foreign origin of goods is a required as a mandatory field per below reg: FTR 15 CFR30.6(a)(11) Domestic or foreign indicator. Indicates if the goods exported are of domestic or foreign origin. Report foreign goods as a separate line item from domestic goods even if the commodity […]

  • Proof of Use Certificate 15CFR 10.138

    QUESTION: We have to provide proof of use certificates for goods that we are legally importing duty-free under 9817.00.50 agricultural use. The imports happen multiple times during the year. We are considering how often to provide these proof of use certificates. For anyone who has done or is doing these certificates, how often do you […]

  • GEN. PROHIBITION 8 DESCRIPTION

    QUESTION: I am putting together a chart for employees explaining what the 10 General Prohibition mean to help them clear country alerts and actions that need to be taken I am having a hard time putting together the correct wording when I come to Gen Prohibition 8 Under the prohibition you cannot export or reexport […]

  • LCL DG Cargo Acceptance

    QUESTION: We have a product that is classified as UN3481- Lithium Ion Batteries Contained in Equipment and falls under Special Provision 188 (IMDG). We have not been able to get any forwarders or ocean carriers to accept this freight for LCL cargo out of China or Taiwan. Does anyone have an explanation as to why […]

  • RESTRICTED VS UNRESTRICTED ENCRYPTION

    QUESTION: Can anyone provide me a definitive answer as to what criteria the DOC uses to determine whether an encrypted part is Restricted or Unrestricted? A review of the regulations does not provide a straight forward answer to the question.  What I am looking for is that “elevator” answer you can give your boss when […]

  • NON-US COMPLIANCE RESOURCES

    QUESTION: Is it a common practice among U.S. based companies to employ a non-U.S. employee say in MX or IN to handle U.S. imports/exports/FTA qualifications? ****************** Answers: Based on past experience, a two part equation works well, the first on is having locals (non-us) resources sorting through the compliance details for each country and the […]

  • THIRD PARTY RISK ASSESSMENTS

    QUESTION: When utilizing a 3rd Party Software Management system to screen business partners; Agents, Distributors, Toll Manufacturers as such could we have your feedback and suggestions  on the criteria you may have used to determine who should be screened? ************* Answers: All customers, vendors, suppliers should be screened against restricted/prohibited party lists Outside 3rd party […]