Question: How are companies managing the requirement to log technical data exports under the EAR? Are you logging the export of technical data for everything; everything except EAR99 technical data; or only licensed technical data under the EAR? ========== Answer: Not sure what requirement you are referring to? Are you thinking of the 762 recordkeeping […]
Question: We recently had a shipment, sent via express courier, stopped in El Salvadoran customs. They requested an invoice in excel format for clearance. We don’t issue invoices in excel because they can so easily be changed. Has anyone had this problem before? Express courier indicated that this was now common in several Latin American […]
Question: When we do Customer Routed transaction the best approach is to use an SLI and let the broker/forwarder file the AES? When customer routed the forwarder and purchaser would then have to supply each other with a Power of Attorney correct? ********** Answers: If you sign the SLI, you will be authorizing the freight […]
Question: My company is a wholesaler/distributor and our customers want us to export the merchandises but we don’t have title of the goods. I think we can do that but can the member give me what are the risks involved ? ========== Answer: Much more detail needs to be known here – also underlying contracts […]
Question: We are about to start exporting to China on a regular basis. I need to know the requirements for certificates of origin. Are they required? Can we create a blanket certificate? Does it have to be stamped by our local Chamber of Commerce? Is there a better way? *************** ANSWERS: The China customer should […]
Question: A Mexican customer has advised that they want the Tax ID number of the our company (US Seller/Shipper) to be listed on the invoice to be used for customs clearance into Mexico and they said it is a requirement but when we asked our Mexican Broker about this, they said it is not a […]
Question: We have been asked to approach OFAC to obtain a General License for our Europe operations to ship to Crimea. This license would be for USA origin goods that are consider EAR99. The goods are initially exported from US and sold to our Europe intercompany location. The goods come to rest in EU territory, […]
Question: We expect to receive a license to export (to a wholly-owned sub in a CB2-controlled country) all development, production and use technology for a certain product. After we get the license and export this technology to the foreign sub, we expect that employees of this foreign sub, who are citizens of that local country, […]
Question: We manufacture electronic equipment that we have designated as EAR99. However, recently I was informed that some of our products with this designation contain MMIC power amplifiers. Do we need to make a classification determination based on the MMIC amplifier within the final product, or the final product performance and technical characteristics itself? ========== […]
Question: We are a US company who usually sells product through an agent in Canada, but occasionally we will send no charge samples, or urgent warranty replacements directly to customers. There is not currently in-house agreement to provide a POA for our courier to clear the goods on our behalf in Canada, so DDP shipments […]
Question: Does the term ‘licenseable’, in the export compliance context, include shipments that qualify for license exceptions or exemptions, or does it just refer to shipments made under a formal license. Big debate around here among the compliance geeks. ************ ANSWERS: Licenseable means the NEED to get a LICENSE Exemptions and Exceptions ELIMINATE the need […]
Question: Our compliance department has been tasked by our sales department to provide country specific information and potential hurdles regarding the following two products to six Asian countries: Products: 1) formed scallops (Argentine scallops formed with a binding agent [0.95%]; and 2) bacon wrapped scallops Countries: Hong Kong/Japan/Malaysia/Singapore/South Korea/Taiwan As this is my first […]
