• EXPORT DATA RISK ASSESSMENT

    Question: There are several risk mitigation reviews taking place in my organization.  I was tasked to look at our export process for information exchange.  For example: We are a US company and have servers in Penang, Malaysia and Toronto, Canada, that store US EAR export controlled data.  The owners of the data most of the […]

  • EXPORT IDENTIFICATION

    Question: Was curious if the following scenario is considered an “export”. 1.       U.S. Citizen works full time in our Maquila operation in MX. 2.       U.S. location has a customer drawing subject to the EAR (pending ECCN from customer). 3.       U.S. location must allow U.S. Citizen in MX to review the drawing to determine if the […]

  • KORUS ENTRY THRESHOLD

    Question: Article 7.7  ( Express Shipments ) of the Korean-US  Free Trade Agreement states that “{ ..} no customs duties or taxes will be  assessed on, nor will formal entry documents be required for, express shipments valued at 200 U.S. dollars or less.” This section, however, does not clarify if this applies to only products […]

  • AUSTRALIA EXPORT CONTROLS

    Question:       Anyone know what type of export control regime is in place in Australia?  We acquired a company in Australia that we are integrating into our global compliance program.  We’ve  learned that there is a version of an HTS code that must be declared on their version of an export declaration.  We’ve […]

  • SEPARATE LICENSE EXCEPTIONS Additional Answers

    Question:   I’m looking to the membership’s expertise to confirm this. Is a License   Exception required for each Reason for Control in order to avoid having to   apply for an export license? Example if an item is controlled for NS, AT, and   EI reasons, does the exporter have to find a license […]

  • ARABIC LABEL REQUIREMENT FOR EGYPT

    Question:       Does anyone have experience in shipments to Egypt ?   according customer we should provide our cartons / products with Arabic   written labels, including importer name, name of the item and the origin of   each item.  It seems to be an official instruction of the Egyptian customs.   Are […]

  • EXPORT REQUIREMENTS FOR KITS FOR AIRCRAFT

    Question:   We ship kits called Service Bulletins used to modify a section of an civil   business-type aircraft.   The kit is imported as a kit and may comprise several different   parts.  The import classification is based on the “essential character” of the   kit which would be the most important item in […]

  • EXPORT MARKING

    Question:   What are the U.S. Export requirements for the marking of product and/or containers?  Is country of origin labeling required when exporting from the U.S. Is there a certain regulation within the EAR that sites this?   ===========

  • EII DATA ELEMENTS

    Question:   For those of you who use freight forwarders to file your EEI, how do you provide / recommend to provide the required data elements to the forwarder? I’m specifically thinking about HTS/Schedule B classifications and origin – these aren’t standard fields on our invoices. Do you use a different approach for standard vs. […]

  • USPPI

      Question: We often sell to a domestic customer which asks us to export directly on their behalf. When I see this, I ask if we are shipping to a repair shop/maintenance facility for them or if our domestic customer is selling the product as part of the transaction. If it is sold, I let […]

  • TOOLS OF THE TRADE FOR EXPORT addt’l answers

    Question:   We have hundreds of parts/equipment being used to support offshore activities which will be returned to the US(within 1 year of export)   Note: A Carnet cannot be used to this particular country.  Instead of calling out 40+ HTS’, is there an export provision that allows for the use of Tools 40+ of Trade?   […]