Question: Hi, We have a XRF machine that identifies and measures metal and element content on items. It was manufactured in China. We need to send it back for repair. I am told it is an EAR99 item. My concern is that it may need a license to go to China. How can you send […]
Question: Is anyone aware of ways to minimize the impact of the tariffs on imports of pharmaceuticals into China? Someone suggested importing them into Hong Kong instead? Answer 1: China has already exempted certain pharmaceuticals from their 125% retaliatory tariff. You’ll need to work with your local broker or Customs at the port, since this […]
Question: Good day all. I am a Licensed Customs Broker for a long-time importer account sourcing in CN and shipping subject to 301 provisions. The HTS is 6902.20.1020 refractory/ceramic shapes, and under 301 I have added additional 9903.88.03 with no previous issues. Shipment is one of two that fall under exclusions to the additional 10% […]
Question: Has anyone heard what the guidance is going to be to “certify” to Customs what the export or laden date is to fit this March 7 window? Not sure why the laden date on the BOL or AMS wouldn’t suffice but there are some out there stating there is going to be some sort […]
Question: Odd question – how do you create a MID code if the manufacturer is unknown? We acquired thru a lawsuit an item that was used to manufacture counterfeit versions of our product in China. The item is in possession of one of our authorized manufacturers in China currently. We would like to import it […]
Question: Hi Everyone! My question is for interpretation of the value limit in 15 CFR 748.10(a)(3) for requirement of a PRC End User Statement. The requirement says “Any commodity(ies) requiring a license to the PRC for any reason on the Commerce Control List, and the total value of such commodity(ies) requiring a license exceeds $50,000.” […]
Question: Does anyone know where to find a comprehensive, updated list of US companies that China has sanctioned? Answer 1: Opensanctions.org has three lists: Chinese Unreliable Entities List (UEL) – OpenSanctions Here are their names in Chinese. That may help with a Baidu search. The Unreliable List – 不可靠实体清单 The Countermeasure List – 反制清单 The […]
Question: Hi All I work for a software company. Customers download their software and keys from a secure website. I inherited a process that’s causing me some concern – if a customer requests it, we will send them their software on media (DVD or USB drive) in addition to making it available for download. All […]
Question: Good morning, members I recently started working for a new aerospace company that mainly does commercial items that fall under 7A994 and 7D994. The only control for those items is AT but some of our sales are to Chinese and Venezuelan Civilians (no military). Can we still use NLR as both countries are not […]
Question: I have a foreign made item that I have determined is not subject to the EAR based on FDP rules. The item is EAR99 and all items in the bill of materials are EAR99 so therefore there is no controlled US content. This item is used for gas and chemical delivery systems incorporated into […]
Question: Greetings! I work for a company that manufactures EAR99 items that contribute to “The “development” or “production” in the PRC or Macau of any “parts,” “components,” or “equipment” specified under ECCN 3B001, 3B002, 3B090, 3B611, 3B991, or 3B992.”. Since the new regulations of 744.23 in Oct of 2022 I have received mixed responses from […]
Question: I had a discussion with a customer that is looking to import some material from China to Mexico but would like to take possession of the material at a US port and then import to Mexico. We will drop ship the product from China. The customer claims that since it is a temporary transaction, […]
