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 […]
Question: We are a company in the biopharma area who exports cell culture cells from the US to various parts of the world. The cell culture cells were purchased more than 10 years ago and we don’t have accounting data to verify the original purchase price. Sometimes we have difficulties with importation as the value […]
Question: We are a small telecom/networking company in CA. I am coordinating a shipment to Russia. Incoterm is EXW. The ultimate consignee in Russia is routing the goods through The Netherlands, then on-forwarding them to Russia. I asked if they are shipping into a bonded warehouse in NL, they said yes. I asked what entity […]
Question: Could we, as a US company, submit a CCATS ruling on behalf of another (foreign) entity? We need ECCN classification for software from a small German vendor who is clueless about US export controls. We’re unwilling to classify the software ourselves b/c of potential controls, but we wouldn’t mind assisting with a CCATS application. […]
Question: I am responsible for approving customers for my company. I must screen the contact and company via our screening software and obtain an End User Cert completed by the customer in order to approve them. I have encountered a few different parties which appear to represent that they work for a company that they […]
Question: Could we, as a US company, submit a CCATS ruling on behalf of another (foreign) entity? We need ECCN classification for software from a small German vendor who is clueless about US export controls. We’re unwilling to classify the software ourselves b/c of potential controls, but we wouldn’t mind assisting with a CCATS application. […]
Question: Scenario: Foreign Buyer (FPPI and Ultimate Consignee) purchases goods from a US Vendor. FPPI controls the movement of the cargo and instructs US Vendor to ship the goods to a US Warehouse unrelated to US Vendor. The US Warehouse is used by a related US company of the Foreign Buyer. The goods will be […]
Question: Does anyone have very specific screening procedures/policy which you would be willing to share? I often have a difficult time choosing where I draw the line regarding the end of my research/due diligence on a given party to be screened. Do you strictly screen the individual name of the customer point of contact and […]
Question: Our company has a fleet of product demonstration vans that travel the US loaded with product (hand tools) and giving product demonstrations to potential customers. We are preparing a similar van for use in Canada, but have had some demonstration possibilities come up before the Canadian van will be ready. We are trying to […]
Question: At http://export.gov/ecr/eg_main_023148.asp, it states that parties listed on OFAC SDN with certain designators (SDGT, SDT etc.) are subject to EAR licensing. I had “assumed†all on the OFAC list would be subject to OFAC licensing.    1)   Does it say this in the EAR anywhere? 2)     Are all the other […]
Question: Using 9801 when importing U.S. Goods Returned is optional.  If you want to pay duty, CBP won’t complain. But can anyone confirm whether the use of 9801.10.0000 is optional when reporting the export value of repairs in AES? Can we use the “normal” HTS/Sched B if we want? Section 30.29 in the FTR uses […]
