I have received a ruling from BIS for one of our machines that the ECCN will be 2B991. We can apply for a license, but can not be guaranteed it will be granted. How do other companies deal with the aspect if you want to quote business in a country that requires the license, you […]
May a product be exported from the US if the country of origin is unknown? If so, is it acceptable to enter “unknown” on the documentation as the country of origin?
Exporters haven’t typically made “disclosures” like importers do, when dealing with basically “data” glitches, such as a value that was slightly off or a wrong HTS. With the newly enacted higher penalties for export violations (“International Emergency Economic Powers Enhancement Act” – S. 1612), are members considering getting more “radical” to institute a robust “export […]
I am in the process of establishing our export compliance controls and I am having a hard time understanding how export shipping documents are compiled for record keeping. On the import side we have ACE but on the export side I can’t find any means to extract this info. I was able to obtain one […]
Should End User Cert’s be requested for every export shipment sent internationally? If not when?
I have reviewed the Answer Database on these issues and, while some info is helpful, it is a bit generic. I hope that someone out there has faced these citizenship/HR issues before and can assist. We are trying to set up a process for HR to begin obtaining citizenship info on a global basis for […]
I’m presently working on implementing a ECP (export compliance progam). As part of this program I want to audit the freight forwarders (althought distributors designated) to make sure they are filling/filing correct SED and to make sure that our goods are going to where our distributors are telling us. We are the PPI, we ship […]
Does anyone have an export forwarder compliance audit checklist that can be made available to the membership?
Have any members had the experience of consolidating their related companies into one facility, but not consolidating the IRS #’s? How was compliance brought in in order to manage this when the different IRS #’s had different compliance groups? How were the exports shipped out especially when it was the same shipping dock?
I am looking at the new China Policy Rules. I am confused as to when I would Apply for the Validated End User Program (VEU). We used Contract Manufacutures in China. The items they recieve don’t require a license. Does the VEU only apply to when a license is required?
Our company may begin using an FTP or SFTP process to update software on machines that are located at customers throughout the world. I’m interested in identifying best practices in use by other company’s in this same situation. In particular, what are some methods to appropriately send the export control diversion statements, screen for licensing, […]
Our company has semi-finished product which we manufacture in the US and then ship to our subsidiary warehouse in China where it is stored and distributed to our customers as needed. One of our customers in Asia buys this product directly from our chinese subsidiary and then goes through a process of finishing and packaging […]
