QUESTION: I have been tasked with creating and managing an export compliance recordkeeping system/procedure. We have Sales Representatives (independent contractors) that represent and sell our products all over the world. Are these Non-US citizens, selling US origin products (manufactured in the US) subject to the recordkeeping requirements of BIS part 762? ========== Answers: Yes ========== […]
QUESTION: I would like to ask the membership to assist with comments and guidance regarding License Updates. We currently have BIS issued licenses for U.S. Produced products destine for China. The purchaser and importer in China is a related party. We in the U.S. have been notified that 4-of the current warehouses in China will […]
QUESTION: Has anyone seen 2017 Schedule B numbers? I know 2017 HTUSA is out but I have not seen the schedule B numbers yet. —————————— ANSWER: The Schedule B numbers have not been published yet. Per the US Census Bureau, they should be available by next week or by the end of the month […]
QUESTION: Does anyone know if it’s legal to export cars (including new and used) from U.S. to China? There were some articles on the website saying it was illegal to export luxury cars into China. ———————– ANSWER: Depends on what you mean by illegal and which country’s laws you are referring too. In the […]
QUESTION: If exports from the US are sold by an *offshore* legal entity, who would be the USPPI? —————————— ANSWERS: A bit more information needed. But assuming you (in Us) selling goods to offshore entity, then you are still the USPPI and the value invoiced to the offshore entity is the basis of the export […]
QUESTION: We are in the process of bringing our export filing in-house, and I wanted to benchmark how other members handle the collection of accurate (or even semi-accurate) inland door-to-port freight charges. We export under a variety of different scenarios. For example, we may… ship on our contracts on a door to port basis, […]
QUESTION: Currently, all of our export transactions that ship from the U.S. have a DCS (destination control statement) on the Commercial Invoice. A portion of our U.S. origin products are sold to a related party and warehoused in Europe for subsequent exports in Europe as well as outside of Europe. Should a DCS be used […]
QUESTION: Has any once noticed that automated emails are no longer being generated by ACE when direct export filings are made? Previously we received an automate email with subject line AES Direct Filing – Shipment Ref #. Email auto generation stopped for us beginning 12/1 and ACE support responded that no changes were made […]
QUESTION: Company A is an U.S. manufacturer for ITAR or EAR controlled items, and has ITAR registration. Company B is a foreign customer. Company C is a U.S. company and is Company B’s broker and exporter of record. If Company A knows that Company C does not has proper export licenses and A has informed […]
QUESTION: It has always been my opinion that software downloads from the US to another country are considered “exports”. That is, if I sell software to someone I know is outside the US, and the buyer downloads it from my US site, that transaction is an export by me. If that is true, […]
QUESTION: In applying for a US Export License for 3A001 ADCs to China the End User states that they cannot provide complete product specifications for the electronics assembly they are building because of IPR concerns. Is this a Red Flag? The documentation provided showed a block diagram with English translation showing the ADCs […]
QUESTION: There is a debate with regard to import of Foreign Classified ITAR controlled technical data.We have one person that says a DSP-85 is required. DSP-85 by definition is “Application/License for permanent/temporary export or temporary import of classified defense articles and related technical data”.You cannot truly temporarily import technical data. I assume the intent of […]
