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, […]
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 […]
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 […]
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 […]
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 […]
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 […]
Question: Does anyone have a template letter to send to distributors to remind them of US export regulations and restrictions on exporting to sanctioned parties? ========== Addl Answer: If you would like to contact me directly I will send you our End User Cert language which may help. You can also do an online search […]
Question: We have come upon a new business scenario and I’m looking for guidance on the documentation requirements. We are having a product made in Thailand and are responsible for shipment of all raw materials (some from US, some from other countries in Asia) that are sent to the Thai manufacturer. Upon completion of […]
Question: I need to ship general export/telecom equipment overseas to our sales team in UK so they can use it for demonstration purposes only – no commercial transaction. I can import under our UK subsidiary. Value is over $2,500 USD. Would our UK subsidiary be the USPPI? Do I indicate that USPPI and foreign entity […]
Question: We are looking to implement a database to consolidate and streamline import and export information globally (such as: HTS / ECCN classification, Customs descriptions, OGA requirements, etc).Based on the following criteria: 1 Part # = Multiple country HTS codes, Customs descriptions, OGA requirements, etc. Approx 30,000 part # per country Database would be in […]
Question: When shipping a laptop or smartphone out of the country (not hand-carried), we determine the ECCN for each piece of software contained on the device in addition to the device itself. I’m wondering how this should be declared on exporting paperwork and the AES filing (when needed)(i.e. does the software need to be listed […]
Question: When shipping a laptop or smartphone out of the country (not hand-carried), we determine the ECCN for each piece of software contained on the device in addition to the device itself. I’m wondering how this should be declared on exporting paperwork and the AES filing (when needed)(i.e. does the software need to be listed […]
