Export Compliance

Questions and answers about Export Compliance

  • Shipping personal items to Germany from the US

    QUESTION: Looking for guidance from the membership.  My company is sending an ex-pat to Germany and their personal items need to ship.  Total value of the shipment is about $350 USD. What is the best way to get these items past German customs? Items are keyboards, office supplies and disinfectants. ========== Answer Each customs agency […]

  • Answers to QUESTION ON EXPORTING ON BEHALF OF DOMESTIC BUYER

    QUESTION: My company is a distributor, with a majority of sales activities occurring to resellers. Sometimes in the course of a domestic sale, the reseller would prefer that we ship their purchased goods directly to their foreign customer. Further, we generally have very competitive rates with our carriers, better rates than most of our domestic buyers may […]

  • Answers to QUESTION ON EEI FILING EXEMPTIONS

    QUESTION: Does §30.37(a) supersede §30.36? Can we use exemption §30.36 when exporting NEW vehicles to Canada? The note under §30.37(a) Miscellaneous exemptions state the following: Note: this exemption does not apply to the export of vehicles. The export information for vehicles must be filed in AES regardless of value or country of destination. It is clear exemption §30.37(a) cannot be used for vehicles even if they are being exported to […]

  • Answers to QUESTION ON ITAR AND MAQUILA

    QUESTION: Companies that manufacture ITAR products in a maquiladora/IMMEX – anyone know how many do this, is it common? How do they set it up, avoid risks? **************** Answers: You will need to obtain a Manufacturing License Agreement from the DDTC. See 120.21 of the ITAR ***************From my understanding based on past experiences, rare or […]

  • Answers to Question on MEUses and MEUsers

    QUESTION: I plan on shipping an item enumerated in the CCL to a Military End-User (Coast Guard- not in China, Russia, or Venezuela). Based on the reasons for control for the ECCN and the country of ultimate destination, a license would not be required. However, because of the update to the definitions of Military End-User/Users, […]

  • EXPORT CONTROLLED DOCS IN CLOUD

    QUESTION: We have technical data documents that are export-controlled and are currently stored on local servers. Is it permissible (after any appropriate licensing) to use a cloud storage solution based outside the U.S.? **************** Answers: While in the past, storing technical data outside the US was considered an export by both Commerce (EAR) and State […]

  • EXPORT COMPLIANCE PROGRAM

    QUESTION: NOTE: members MUST reply directly to: krhoads@proofpoint.com Has anyone has recently rolled out an Export Compliance Program, or, have a solid ECP in place and is willing to share their experience and knowledge. We have a solid, but rough framework in place using the ECP Guidelines from BIS and other various publications.  Yet, would […]

  • DECLARING CORRECT EXPORT VALUE

    QUESTION: I am new to managing logistics/trade compliance for a cybersecurity company that provides mainly saas based products. On occasion, we ship appliances/servers with imaged software to international locations.  We use the invoice to note the sale price of the imaged appliance for shipment value.  Often though,  the invoice contains other saas products and service […]

  • DECLARING CORRECT COUNTRY OF EXPORT

    QUESTION: I am having a discussion with my Customs Broker on what is the correct declaration for country of export on a recent shipment.  Scenario-  one shipment from a  vendor in Germany. Ex works Germany, forwarder located in Netherlands and sailed from Rotterdam, House bill shows pick up location as Germany, port of export Rotterdam..  […]

  • MISCLASS OF EXPORTED MERCHANDISE

    QUESTION: I’m hoping someone can shed light or point me in the right direction regarding the potential misclassification of export merchandise.    All of our company’s products are EAR99/NLR so there is no matter of licensing; we also have a denied party screening program in place.   However, some of the items being exported are assembled into […]

  • IMPORT-EXPORT MANUALS

    QUESTION: If a company does not have an import-export (trade compliance) manuals what are the consequences with CBP and BIS? Are there penalties? Do I need to emphasize with management the need and/or requirement for these documents? Are corporate manuals and SOPs with brokers and freight forwarders mandatory? ************** Answers:No, they are not “mandatory”, and […]