Question: For the following scenario, when would the US HTS and US ECCN need to be declared. A non US customer orders a “virtual programmed credential”. This credential, or virtual smart card, is not physically shipped from the U.S. plant. It appears on the invoice to a non US Customer with other physical and tangible […]
Question: I have come to find that the company has a practice of adding 25% to the freight charges on export sales / shipments, when the shipments are under “prepay and add” (incoterms DAP, CPT, CFR). I have also found that the company practice is not to simply ensure they are fully capturing all freight […]
Question: Say I export my product (EAR99) to Germany. At this point I file AES with NLR. A couple of months go by and learn that that product is going to a sanctioned country where an export license is required. If I knew that the product was going to be on-forwarded to a sanction country […]
Question: I was performing an audit at a fulfillment warehouse and came across some exports that are odd. As a fulfillment warehouse we manage the inventory for our customers who are either the USPPI or the IOR. We have no title to the goods and the primary function is to receive, package, store, distribute […]
Question: Would anyone in the membership be willing to share a template for an Export Compliance Manual? I’m aware of the guidelines provided by the BIS, however, I’m looking for assistance to get started in the form of a complete template. *********** ANSWERS: http://www.exportrules.com/ *********** Boskage Commerce has an Export Policy and Procedure Manual.
Question: If our company, the USPPI, employs a 3PL to ship and file EEI for our exports, should that 3PL be listed in AES Direct as the Freight Forwarder? (The 3PL in these cases is not performing a freight forwarder function. The 3PL is not booking cargo space). If the 3PL should be listed as […]
Question: One of our US divisions is shipping an item from the U.S. to Pakistan. The buyer is our China division and the final sale is taking place in Pakistan. Our China division has asked if the ocean bill of lading can show them as the shipper and they will provide the invoice and packing […]
Question: I have not seen any new guidance on FTR 30.6(a)(17) (EEI value), and I just wanted to check if anybody else had a nice, realistic method for compliance since I am sure you are all following it with Ts crossed and Is dotted. For those unfamiliar, the value reported for EEI (AES/SLI/SED) is supposed […]
Question: I am working on an Export Compliance policy. Our products do not require a license. Has anyone in the membership considered this scenario in their Export Compliance policy? How do you handle this type of scenario? I am trying to determine if we need to modify our export filing based what the consignee shows […]
Question: Does anyone have any experience transshipping from Mexico US EU, while maintain the EU MX FTA benefits? Were you able to procure a form CBP or another party that would satisfy the non-manipulation requirements required to claim the FTA? Thanks! ************ Answers: More detail needed as you did not explain what you mean by […]
Question: My company sells/exports EAR99 items as a general rule, no licenses, no high risk countries,and we run the DPL checks daily.From time to time our suppliers will submit a request for us to complete an end use/end user certificate.When I review their commodities, they are clearly EAR99 (plastic parts, metal parts (automotive)), no electronics […]
Question: If we send shipments out of Puerto Rico to other Insular Possessions or Islands, it’s my understanding that these shipments are under the same U.S. export regulations as if they were shipped from the states, is this right? If we ship from the United States to an Insular Possession, it’s my understanding that these […]
