QUESTION: We sell some of our product through 3rd party distributors in other countries. We have a standard export compliance due diligence questionnaire that we send our unrelated 3rd party distributors. One of the questions is: “Do you conduct any screenings against an authorized denied party or restricted party list published by your government, […]
QUESTION: To define the ECCN for Valves that we use for Oil and Gas Production, will it still be under 2B350.g, IF it is NOT intentionally designed for use in Chemical Manufacturing Equipment? We would appreciate if we could get deeper insights into this. ========== Answers: No. You need to analyze the materials […]
QUESTION: If items subject to the EAR are exported to Country A and then subsequently re-exported to Country B, is the re-exporter required to include the Destination Control Statement on their export paperwork? ========== Answers: If the items are U.S. origin, yes. Do companies overseas adhere to it? Most likely not, but I am seeing […]
QUESTION: My company is inquiring whether they can ship a U.S. medical device to a medical trade show in Saudi Arabia where it will be picked up by an Iranian customer. The Iranian customer will then take the medical device back to Iran. I am aware that medical devices can be shipped to Iran under […]
QUESTION: My company has a foreign customer that we export to. My company completes all of the export documents and files the EEI and receives the ITN. We then release the shipment to the foreign customer’s designated freight forwarder who handles the export move. Would this scenario be considered a routed transaction? ========== Answers: This […]
QUESTION: Our supply chain has developed a process (without my participation) for shipments to our ex-US warehouses which involves the shipping site signing the commercial invoice and SLI. For drop shipments from 3rd party suppliers, the invoice is manually created by the invoicing department, and the invoicing department is signing the documents. This concerns me, […]
QUESTION: We have been asked to change delivery terms on sales to a Mexico client from delivery at their Mexico maquiladora to delivery at their forwarder’s facility in Texas. To maintain the exemption on the Texas sales and use tax we need proof of export. Not all of the shipments require an EEI. We would […]
QUESTION: If the US exporter sends a tool that is owned by their customer to the exporters Maquiladora, how do you declare the value of the assist? ========== Answers: While the information is not very detailed understand that anytime a tool, product, raw material or other type of material is provided “Free of Charge” it […]
QUESTION: I was curious if anyone in the membership has found a way to pull data out of the ACE Portal for US exports to Canada? My companies exports are not ITAR, nor do they require licenses, thus none of the standard reports pull any data. Are there any data points in ACE for Canadian […]
QUESTION: We have submitted and gotten and approval for our export license with a typo in the zip code, do we need to re-submit and obtain a new export license to show that the correct zip code? Facts: The EUC contains the End User’s correct zip code in their letterhead. BUT under EUC information […]
QUESTION: How does the membership handle domestic sales where they are asked to ship outside the US (destinations other than Canada)? I have a US customer that has asked me to ship to their customer outside the US. How is the EEI filed? The US customer would the USPPI in this situation but I am […]
QUESTION: The scenario is shipping automotive parts, US finished goods(EAR99) to a subsidiary located in the EU. I have read through 31 C.F.R. 560.215 showing prohibitions to Iran. There is an exemption under General License H that allows you to ship items that don’t have a license. However, on Oct 13, 2017 President Trump chose […]
