Export

Questions and answers about Export

  • DOMESTIC SALE FOR EXPORT

    QUESTION: We ship what we call a “domestic export”.  We are a USA company, selling to another USA company, where we know at the time of selling the product it is going to be exported.  The company we sell to is always the USPPI. If our product needed a license, the USPPI would be responsible […]

  • ITEMS EXPORT CONTROLLED FOR AT REASONS

    QUESTION: Looking at the Commerce Control List (CCL), many items are controlled solely for “AT”, or Anti-Terrorism reasons. Consulting Supplement Number 1 to Part 738 of the EAR, we find precisely ZERO countries with AT Column 1 or AT Column 2 licensing requirements.  What’s the point of this type of control (probably one of the […]

  • DOCUMENTING FREE OF CHARGE EXPORTS

    QUESTION: We have a customs situation where the customer’s invoice is different from the Commercial invoice. The discrepancy is due to some items being “free of charge”.  How does your company document these “free of charge” values when exporting? =========== Answers: A value “for customs purpose” must be declared for any items that are “free […]

  • Is this a Routed Export Transaction?

    QUESTION: We are an international company that exports from the US to our related entities in 15 different countries. Essentially, our export is also our import. We have a global FF service provider that we use.  The US parent negotiates rates with the FF service provider. Our logistics department is small and we have a […]

  • Maintaining Export Screening Records

    QUESTION: When conducting denied party screening on foreign customers, what is required to be maintained for recordkeeping purposes? If you are a smaller/newer Exporter, and not yet able to purchase or subscribe to a software program to screen, what is the best way to record that screening was conducted? If you are using the Consolidated […]

  • EXPORTING TO PAKISTAN

    QUESTION: I am told that it is standard practice in Pakistan for the importer to pay a substantial deposit to the foreign seller under one invoice, and then to request the seller to send a separate invoice for the balance of the shipment. ************** Answers: The best resource for you would be to contact the […]

  • COO FOR US EXPORTS

    QUESTION: How do we file the EEI and export few small value items out of U.S. if the information about their country of origin is not available? They are lying in inventory since many years, and they also do have country of origin marking. If the Schedule B value is less than $2500 and we […]

  • Licensing responsibility and liability for export

    QUESTION: My US company plans on selling technology subject to export licensing (commercial application only; no military/proliferation) to another US company which is controlled by a Chinese company. The transaction would be a domestic sale, but we have knowledge that this technology will be made available to China nationals/ exported to China. Would the licensing […]

  • ERP set up / implementation Value, origin, ECCN, Country and License requirements

    QUESTION: I am working with our ERP team to automate our export documentation and EEI filing processes.  We are developing the format for our export documentation and EEI filing requirements so that our FFs can pull data from our documents (no separate SLI required).   We want to develop a process that triggers when an EEI […]

  • CONSOLIDATED EXPORT REPORTING

    QUESTION: We export consumable goods used in the medical/dental field.  All of our products are EAR99 and most of the shipments are routed transactions.  We use  foreign distributors for our products.  The distributors will often hold the shipments at their forwarder location in the US, consolidate with orders from other manufacturers and then ship out.  […]

  • FPPI File EEI?

    Your Social Security Statement QUESTION: We have a new routed export customer in Puerto Rico. Per our export compliance policy, we have asked them for a copy of the POA between them and their US freight forwarder for filing EEI. The customer did not understand why we were asking for this and I advised that they contact the freight […]

  • Routed Exports – FF Filing EEI’s on behalf of FPPI

    Your Social Security Statement QUESTION: I would like to get advice from other businesses on how they manage working with freight forwarders that are hired on behalf of the FPPI.  The situation we have at my company is about 95% of all outbound shipments are routed exports.  We reach out to the Freight Forwarder that was […]