Question: We are considering selling / shipping food additives made in our foreign subsidiary’s plant to Iran using an OFAC general license for agricultural commodities. To meet the definition of “food,” in the following section below, do “food additives” have to provide “nutrition” to humans in Iran to meet the definition in 31 CFR 561.327? […]
Question: I am being asked to provide an Export Trade Control Order (Japanese regulation) certificate for a certain product. While I’m able to find information online about the Japanese Export Trade Control Order, I’m unable to find any information related to a certificate pertaining to this order. I’m also unable to find any examples. The […]
Question: Imported products with quality issues are returned to vendor where the vendor appoints a forwarder to act as U.S. agent. The term of the return is FOB U.S. port and product is EAR99. What is the best practice for importer (USPPI)? Who files AES? Who is the shipper on B/L (USPPI, FPPI or forwarder)? […]
Question: I did an export to our 3PL in Vietnam from the US and on my commercial invoice and packing list I made a mistake on carton count. I corrected the mistake and sent revised documents to the receiver, however, they are stating that since the cargo already came through their customs in Vietnam that […]
Question: What defines a company as the actual “Exporter”? Am I the Exporter if I ship to a foreign address under “FCA my dock” Incoterms terms? Am I the Exporter if I ship to a foreign address but am paid by a domestic customer? ========== Answers: What defines a company as the actual “Exporter”? NAFTA […]
Question: Would a 5A002.a.1 item still qualify for license exception ENC when the end user is a non “government end user” (private sector) located and headquartered in India (not listed in Supplement 3 of part 740)? Any advice or suggestions are appreciated. Per CCATS, the item’s reasons for control are NS1 & AT1, and ENC […]
Question: I am not familiar with casting/molding so the terms are throwing me off, but we want to export sand insert cores as well as some samples to a potential supplier for testing. The inserts are compressed silica sand coated with phenol-formaldehyde. Aside from my doubts that they will arrive in one piece, I don’t […]
Question: Who should be the USPPI (U.S. Principal Party in Interest) and exporter of record for an export shipments being done by a Foreign Entity Company exporting under bond? The scenario is a Foreign Entity Company with an importer number will be importing raw materials in bond to the US under the Free Trade Zone […]
Question: We sell snack foods into Canada that are imported and shipped directly from Europe. We take ownership in Germany, and issue the commercial invoice to the Canadian importer from the US. Payments are made to us in the US. Is this considered an Export from a US perspective, though the goods never enter US […]
Question: For routed exports, we provide a letter to the freight forwarder with the information required by the regulations. Should we include a statement in the letter that this is NOT a POA and that the freight forwarder is not authorized to file AES on our behalf? They should only be filing on behalf of […]
Question: As projects come up, we competitively bid air freight. So there are a number of different forwarders who could have our freight for export. We sign either a freight forwarding agreement and/or provide a shipper’s letter of instruction. If our company handles the export filing via AES, is there really a need to […]
Question: We would like to develop an export control risk assessment checklist/spreadsheet that we can use to ensure we are reviewing all needed areas. Such items we would capture are review of SOP’s, manuals, licenses, classification, valuation, etc… Does anyone have one they would be willing to share? ************ Answers: BIS has published an […]
