QUESTION: My policy is as follows: All shipping documents contain the approved DCS. EAR99 shipments are shipped to the agent of the FPPI and I ask the agent to provide me with evidence of AES filing. If they do not provide evidence after I specifically instruct them to provide, I file the evidence and move […]
QUESTION: I have a situation where we exported a non-controlled commercial item to a company in Dubai. We just found out that company cannot cleared customs because they are not registered with Dubai customs. The importer is requesting to change it to his name so he can clear customs. Freight forwarder informed us that the […]
QUESTION: A forwarder provided one MAWB for 40 pallets moving over 3 different flights spread over three days. Which export date do I use for ACE filing? OR should I ask for three separate MAWB for each flight? ************* Answers: Read 19 CFR 152.1(c) *************** If the shipment is split in advance, on purpose, then […]
QUESTION: I have recently joined a company that has numerous routed export shipments of EAR99 goods. When I say they are routed, the product is delivered to warehouses in Miami, and the foreign buyers work with their US agents to consolidate product with others for main carriage to the final destination. The current process is […]
QUESTION: I’m hoping the ICPA community can provide their guidance on this one. We are a foreign entity in the Netherlands that performs various types of defense services on ITAR controlled military hardware (both SME and non-SME). We were recently added as a sub-licensee under a Technical Assistant Agreement (TAA) in order to perform a […]
QUESTION: I have a dilemma in determining who should be the true exporter of record. My company has an office in West and East Coast. The West Coast office is the physical distribution and export for two different divisions/product lines. We have always exported under West Coast office address and TAX ID. Internally we will […]
QUESTION: My company imports into the US and then exports some of the products into Canada, so I want to look into setting up a duty drawback program. To determine the potential refund amount, I can run the ACE ES-003 report to see the details of all our US imports, but how can I find […]
QUESTION: Asking for any experience people are willing to share of interaction with Czech Republic Customs authorities about the declaration of Country of Origin (CoO) for materials being exported. I am aware of the requirement to declare accurate CoO and that this data is coming under more focus recently due to various trade sanctions. We […]
QUESTION: I know the rules require claiming both ‘D’ or ‘F’ for origin when items of the same HTS code are exported. We manufacture and buy a bulk commodity, but do not have an inventory system to identify how much of the exported fungible good was from a foreign source or a domestic source. Is […]
QUESTION: I have a client who is interested in finding cheaper options for transporting product to the Caribbean Islands from Panama. The client suggested to bring the containers to Miami, then transport it through a 7512 “in-bond’ to Everglade, FL where the product would be repackaged and sorted into different containers, then transported back to […]
QUESTION: We buy products and parts from US vendors and need to export, and those civil products obviously belong to EAR99 and we don’t see any possibility of dual use. However, we have recently learned that the product contains a couple of circuit boards (PCB boards) which had hundreds of various electric components soldered on […]
QUESTION: Company “A” is buying from Company “B” – Company “A” is exporting the goods to Company “C” overseas – In my experience Company “A” is the Exporter – Correct or incorrect? %%%%%%%%%% ANSWER: Maybe. Maybe not. Not quite enough information to go on. Assuming both Company A and Company B are in the […]
