QUESTION: If your company uses a Customer Relationship Management system, what controls do you have in place for export-controlled technology or products under EAR and/or ITAR? We are looking at adding flags for certain categories and customers and generating weekly reports of the new opportunities to review for potential export controls. One of the issues […]
QUESTION: Finance is wanting to invoice some of our customers in other than USD. I know the commercial invoice and SLI must be in USD for AES reporting purposes. If the contract with the customer is for other than USD, and we are invoicing in non-USD, how do I manage the changes in USD due […]
QUESTION: I have been asked to provide copy of the EEI covering shipments from the US to Venezuela as proof of exportation. According to Customs in Venezuela and CENCOEX all exporters from the US are providing the printout of the EEI or the old SED form for CADIVI purposes. According to 15 CFR 30.60 EEI […]
QUESTION: -A shipment was sent to Brazil. The pallets were fumigated. However, it was discovered that the pallets were not marked as such. -The product was allowed entry into Brazil. However, the Brazil government is insisting that the pallets be returned to the U.S. -The Brazil government will not allow for the destruction/disposal of the […]
QUESTION: May a person subject to U.S. jurisdiction export or reexport to Cuba items that include U.S.-origin content, but are not 100 percent U.S.-origin? Persons subject to U.S. jurisdiction may engage in all transactions ordinarily incident to the exportation or reexportation of 100 percent U.S.-origin items from a third country to Cuba, consistent with the […]
QUESTION: Can anyone in the membership advise if an HTS number is required to be on the U.S. shippers commercial invoice for an export going to S. Korea? ********** Answers: It is not “required” by any USA agency to be on the export invoice. However, often companies do put the HTS on the export invoice, […]
QUESTION: When filing an EEI with multiple line items under the same Schedule B Number, often times the EEI filing has different nomenclature than the items on the commercial invoice. For example the EEI filing may state “simulation training equipment” rather than listing the name of each item. Does anyone know of a BIS regulation […]
Question: A US aerospace company contracts with an Indian engineering services company to perform should costing services using US supplied technical data and India supplied should costing software. India then returns the data to the US company along with the should costing results. Note that the data is not altered in any way – only […]
Question: US Company exporter knows 2 FACTS: 1) The part /component you export from the USA will be incorporated into a foreign origin item NOT subject to the EAR (i.e. beneath de minimus) 2) The foreign end item (that is not subject to the EAR) will be exported to Iran. Is this OK, since the […]
Question: Exports to Israel from Malaysia are technically illegal, right? Yet MILLIONS of dollars worth of goods make that trip every year. How are they doing it? Is it legal? Or are we talking gray area ========== Answer: I have done a bit of work in the area if you would […]
Question: We are a U.S Company with subsidiaries and employees worldwide. We have a division that only focuses in Intellectual Property (trademarks & patents) worldwide. So far all of the products we have sent to SNAP-R have been classified with ECCN # EAR99. We just acquired a new brand of products (Pesticides) that are […]
Question: The Exporter/USPPI should be screening many parties to the export transaction. My question is what does a freight forwarder screen? I can only think of what is mentioned on the AWB or SLI (Shipper, Intermediate Consignee, and Consignee), if names (Individuals) are provided, than those names are screened. So the screening to a […]
