• HARD DRIVES TO CHINA

    Question: Can anyone share their experiences with exporting hard drives to China. The hard drives do not require an export license and the value is approx. $200? Can we send them via express courier without any problems to our offices in China? ========== Answer: I’m fairly sure the hard drives would require a 3C certification […]

  • USED EQUIPMENT TO BRAZIL

    Question: We have a production machine that we will be shipping to a partner companyin Brazil. Does Brazil allow the importation of used production equipment ? Must it be certified before shipping by a third-party ? Any other issues we should be on the lookout for ?***************Answers:Here’s a good reference:http://thebrazilbusiness.com/article/import-of-used-goods-to-brazil Depending on the circumstances you may want to consider […]

  • TOOLS OF THE TRADE RE-EXPORT

    Question: This is regarding  a vendor serviceman (from Spain)  came to one of our facilities  to fix their  instrument but he left some tools and parts and asked us to shipped them back (they may be too heavy to carry to the airplane) , he will pay for the shipment. These tools are screw drives, […]

  • ANSWERS TO QUESTION ON DISTRIBUTORS AGREEMENT

    Question: We sell 90% through distributors, and about 20% of that through foreign distributors.  Currently we do not have any export control wording in the agreements, such as:  “Distributor shall comply with all (re-)export control regulations of USA, Japan,  the EU, etc, etc. ”  Would someone share their template for such an addendum to a […]

  • FRUIT RE-EXPORT

    Question: I have MX origin avocados that we need to re-export from the US to Singapore Does anyone know if I need to issue a APHIS re-export phyto, our client says none needed but when we receive from MX-US, a phyto accompanies the shipment What other Docs may be needed ************* ANSWER: Sounds like your […]

  • COMBINING EEI FILINGS

    Question: Scenario: We make a booking with our Freight Forwarder for 10 containers to ship from the US to the UK.  All 10 containers are related to a single sales order and are shipping to the same entity in the same country.  The intention is to have all 10 containers ship under a single ocean […]

  • LICENSE EXCEPTION RPL

    Question: I hope one of our attorney members or other members with experience can offer some clarity regarding license exception RPL.  Specifically, §740.10(b)(2)(i) says: €œServicing€ as used in this section means inspection, testing, calibration or repair, including overhaul and reconditioning. The servicing shall not have improved or changed the basic characteristics (e.g., the accuracy, capability, […]

  • HTS/SCHEDULE B FOR DOWNLOADED SOFTWARE

    Question: We are a multinational software company and like many other software firms the majority of our product is distributed electronically via internet downloads. Typically, software is classified based on the underlying medium (i.e. optical disk, magnetic tape, floppy disc, etc.) on which it is reproduced. Is anyone aware of a Schedule B number or […]

  • SASO REQUIREMENTS

    Question: Has anyone from the membership been able to successfully implement a solution to address the SASO requirement when shipping your goods to Saudi Arabia?  We are getting conflicting information from our “boots on the ground” versus what our brokers are telling us which is creating confusion….enough so we cannot develop a plan to address […]

  • EXPORTER OF RECORD-addt’l answers

    Question: Our sales people are selling product to Canadian customers freight collect out of our warehouse in New Jersey.  It is moving into Canada via truck arranged by the customer. The sales order shows sold to and ship to as the Canadian company. My sales  department position is that title transfers at the warehouse therefore […]

  • EXPORTER OF RECORD

    Question: Our sales people are selling product to Canadian customers freight collect out of our warehouse in New Jersey.  It is moving into Canada via truck arranged by the customer. The sales order shows sold to and ship to as the Canadian company. My sales  department position is that title transfers at the warehouse therefore […]

  • DC AS EXPORTER OF RECORD

    Question: Our affiliate in Mexico is planning on making direct purchase of fashion accessories from a U.S. vendor. Terms will be FCA U.S. port and they want the terms to be FCA Miami, FL,  the location of our Distribution Center. The intention is then to consolidate these goods with the goods coming out of the […]