QUESTION: We have a US owned China entity that sells to a China customer. The China customer takes this US uncontrolled article and assembles it into their product and then sells to a US sanctioned, comprehensive embargoed country. No US content is in the item we sell, but we do have an expatriate living in […]
QUESTION: We have been approached by the Indian Government to provide a quote for valves to be used on warships by the Indian Navy. (seawater is the media) The valves are made of carbon steel and would otherwise be EAR99, but we are not sure how to handle this situation since going to the […]
QUESTION: Any Help would be appreciated as I have only been the ECO / ICO for a year Scenario: Foreign company A purchases goods from USA Company B. USA company B will ship the goods to Foreign company C. Foreign company A is related to USA Company B. Foreign Company A Provides an […]
QUESTION: We sell civil aircraft parts and components to a US company. Our parts are controlled by the EAR under the Dept. of Commerce. The US company’s business is to sell parts to the US military and foreign entities. Conceivably a foreign military entity. Our packing list that accompanies the part to the US company, […]
QUESTION: We are working on creating a new commercial invoice format. Do companies list the ECCN for each item as part of the commercial invoice detail along with the HTS and COO? Should ECCNs be listed on the Invoice as best practice? My understanding is that certain ECCNs are already required to be on the […]
QUESTION: Who is the USPPI? Scenario: USA company A purchases goods from USA company B. USA company B will ship the goods to Foreign company C. Foreign company C is related to USA company A. Company A is not billing C for the goods, and C is not paying for the goods. The only financial […]
QUESTION: I am working in international company – food industry. We export some goods from the United Arab Emirates to Saudi Arabia. Recently I have come across a new language requirements for exports to Saudi. For any EXPORT, IMPORT & TRANSIT IN shipments invoice, packing list should be in Arabic or with Arabic […]
QUESTION: Under routed transaction if the FPPI and USPPI are related parties is it true that a POA is not needed for USPPI to submit AES filing. The incoterm being used in FCA. Not sure if this matters as FTSR and BIS don’t recognize incoterms ========== Answers: First, you are correct, INCOTERMS do not play […]
QUESTION: I have recently seen updates on the Zhongxing Telecommunications Equipment Corporation (ZTE) export compliance controls. We recently received an inquiry from ZTE. It appears that BIS/DOC has extended temporary general license for exports, reexports, and in country transfers to ZTE. We mostly deal with EAR99 products (NLR). When I screen ZTE on our screening […]
QUESTION: Our shipping site asked me the other day if it was a requirement when shipping documents internationally, that we create a commercial invoice and have it accompany the shipment? My initial thought was that every international shipment requires an invoice regardless of what is being shipped. Is this correct? Can anyone point me in […]
QUESTION: A US Company sells goods to a foreign company, which is a related party. The foreign company designates the Agent to file the US Export. The foreign party also designates the transportation to move the goods out of the US. This by definition is a Routed Export transaction, regardless of the companies being related […]
QUESTION: Back in January 2016 Census posted a notice (81 FR 1394) about a “Used Electronics Indicator” being required for exports of items dictated by Schedule B number. I have not seen any more releases about this and was wondering if the membership had any idea on when this will be implemented and has anyone […]
