• EXPORT ULTIMATE CONSIGNEE

    Question: US parent sells to related UK subsidiary. UK subsidiary sells to end customer in UK. End customer details are known at the time of US export. US parent arranges freight forwarding services from door to door. Cargo will be delivered straight to end customer. Incoterm between parent and subsidiary is CIP London. Freight forwarder […]

  • EOR FOR US GOODS RETURNED

    Question: We export US-made product to multiple countries around the globe from the US.  Occasionally, product must be returned through no fault of our customer.  In some cases (i.e. a customer in Indonesia) our customers do not hold a valid export license and therefore cannot act as the EOR from within their country. The goods […]

  • ENC EXPORT REPORTING

    Question: We are not in the encryption business and I know very little about it, but we do have a few parts that we buy and re-sell that are 5A002 and ENC eligible per the mfg supplied CCATS. I have no way to figure out whether these things are exempt from the semiannual reports under […]

  • NIGERIAN SHIPPING RESTRICTIONS

    Question: Will there be any issues with exporting valves and parts from our buyer in the UK to Nigeria? The customer is having issues arranging their own freight. ********* Answers: Not necessarily.  Of course you need to check denied parties and classify under the EAR/CCL as your products may require an export license depending on […]

  • EXPORT SHIPPING PROCESSING

    Question: My company currently has one export shipping station set up that is used to prepare documents and shipping labels for exports (including Canada). The shipping department tried to implement international manifesting on all of the station machines without bringing it up to the compliance department. Fortunately we were able to put them hold until […]

  • EEI FILING TO A BONDED WAREHOUSE

    Question: The company I work for exports our products to a bonded warehouse in China. At the time we export to the bonded warehouse, we do not know who we will ultimately sell the product to.  Our U.S. entity retains title to the goods until they are sold from the bonded warehouse. Eventually, the product […]

  • MALAYSIA EXPORTS

    Question: My company exports strategic items from Malaysia using a bulk permit and a multiple use permit in accordance with the strategic trade act of 2010.  I am still very confused on why an end user statement (EUS) is required for every new ship to address when exporting using a bulk or multiple use permit.  […]

  • GLOBAL EXPORT PACKING REQUIREMENTS

    Question: We are redoing our export packaging.  Does anyone have a table or chart that details trade destination countries marking requirements.  We would like to be as generic as possible, yet still be compliant. *************** ANSWERS: Check the  ICPA website. *************** It can greatly vary based on commodity and also your customer requirements.  Some countries […]

  • EXPORT PERMISSIONS

    Question: How would others interpret the verbiage contained in this sanction? The United States government shall not issue any specific license and shall not grant any other specific permission or authority to export any goods or technology to “x” under  the Export Administration Act of 1979 (50 U.S.C. Appx. 2401;  the Arms Export Control Act […]

  • SHIPPING TO AUSTRALIA

    Question: Is there an event that would drive the following statement to be included on documentation for goods departing the US and heading to Australia:   THESE GOODS ARE NEW GOODS NOT USED GOODS AND HAVE NOT BEEN FIELD TESTED And then signed by the CEO of the company?  For some reason we have this […]

  • 72 HR EXPORT RULE

    Question: Does the 72 hour export rule apply to self-propelled underground construction equipment (i.e. a tired drill, excavator, wheel loader). ========== Answer: Any used self-propelled vehicles as described in 19 CFR 192.1 fall under the 72 hour advance reporting/presentation requirements.  This includes construction equipment.  If your products are classified under HTS/Schedule B’s shown in bold […]

  • ELECTRONIC EXPORT RECORDKEEPING

    Question: We are looking to implement an electronic record keeping policy for our export shipments similar to our current electronic record keeping policy for imports.  Is there even the possibility of electronic record keeping for export documents.  If so, which agency do we request from and what are the regulations? ************** ANSWERS: See the EAR […]