Question: So wondering how Members handle Compliance Risk and communicating the importance. I just recently (about a year) started a new company lower level position (not Management). Very heavy into Exports and a pretty good amount of Imports. I have many years of experience on the import/export side (20years) Import Heavy, some on the export […]
Question: Hi all, New member with what I hope isn’t a stupid question. I’m looking to ship an FDA-cleared device into the US that has yet to achieve FCC certification. We are currently waiting on the results of a waiver request. Is this possible? If so, I’d appreciate it if someone could help with guidance […]
Question: We are a US based company with a factory in China. We have a distributor in Egypt who is purchasing OEM equipment from our factory. The China factory is the shipper, the US based company is the seller. The distributor will be the importer into Egypt. We are selling electronic components that are classifiable […]
Question: Is there a regulation that states the ECCN / HTS must be on the customs invoice or export documentation? A general disagreement continues at my organization. The information is required in the AES filing. Regulations say we have to notify our customer if an item is controlled (EAR/ITAR); however, I cannot find that the […]
Question: The company I work for does not have a compliance department or manual to reference. In my role, I confirm the international orders from our sales team, consisting of US and foreign nationals who are based in the US and internationally. I process and prepare the orders, arrange shipping which may include filing ACE/EEI […]
Question: We are working on updating our Customs Invoice/commercial invoice for export (including border Crossing) and would like to get some feedback on the Harmonized code to include on the invoice. We are discussing in adding the 6 digit level or the 10 digit level from our database. Looking for a regulation and business best […]
Question: Recently joined a company where a sub-set of our international team handling certain product lines were under the impression they had zero responsibility for exports in any EXW or FCA “buyer pickup” transactions. This lack of understanding also means they did not communicate – ever – with their foreign customer’s U.S. freight forwarder or […]
Question: Our company needs to install/deploy a software (EAR99) for a customer that is located in Ecuador, but our Cloud provider do not have any server in Ecuador. As an option we can use Brazil or Mexico servers. Understanding that those two countries are not restricted and the software is not controlled, I think we […]
Question: Hello, We have a customer that wants to incorporate our EAR99 item into a product that will be used by a foreign military, but they will not complete an End-User Statement. However, they want to provide only a blanket “negative statement” stating they and their customer will not use the product or act contrary […]
Question: Hello, We’re working through the process of better streamlining our current End-User/End-Use Statement requirements and overall screening process. We’d like to understand how/when others in the membership have determined to require statements detailing full End-User and End-Use details from customers. Also how are you handling the PRC semiconductor and supercomputer requirements? More detailed questionnaires, […]
Question: 10 CFR 110.8 speaks to items that are US export controlled by the NRC. My question is NRC jurisdiction based. Specifically, if an item is on the NRC list as controlled for export, but it is not exported from the US, but is produced outside of the US and shipped direct to a non-US […]
Question: I work for a small corporation. We handle a variety of non-licensed goods. So, a recent situation appeared: export operations handling orders. – is this a conflict of interest? Where export department is handling foreign orders, taking on a sales role, and ensure export compliance. I see it as an issue since it just […]
