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 […]
QUESTION: I’ve been asked to put together US export compliance training for our foreign subsidiaries. These are a mix of companies that are either wholly owned by the US parent, or majority owned by the US parent. All companies both manufacture their own products in country for sale to their own customers and also […]
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 […]
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 […]
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, […]
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 […]
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 […]
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 […]
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.. […]
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 […]
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 […]
QUESTION: I was auditing some export shipments to HK and found four shipments destined for the same customer, exported on the same day. The value of each was $500, making the total value $2,000. Less than the EEI filing threshold. In addition to the extra shipping and processing costs I am wondering if the reason […]
