• IOR SUFFIX SCENARIO

    QUESTION: We have one EIN but 19 different locations in the US.  We are thinking about having a suffix differentiator for each location in our EIN. Does customs see the utilization of the different suffixes as more risk, less risk or no impact to risk profile? Can the membership recommend a best practices solution for […]

  • Adding another IOR or adding a suffix to an existing IOR

    QUESTION: My company just purchased another company that also imports.  The purchased company is incorporated in Germany with a US office in Texas.  We are dissolving the US company in Texas and still need to import from the German company. Should I create a completely different and new IOR number or should I just add […]

  • CHANGING US IOR PRIOR TO LIQUIDATION

    QUESTION: Can the US importer of record be changed and submitted to CBP before liquidation ? If yes, what CBP form is used. ************* Answers: The importer of record cannot be changed via PSC.  https://www.cbp.gov/trade/programs-administration/entry-summary/post-summary-correction   The only way I know of to correct a wrong importer is to have a second entry with the […]

  • IMPORTER OF RECORD SCENARIO

    QUESTION: Company A (located in Mexico) is ordering parts for Company B (located in Canada) using their Purchase Orders, from a supplier located in Costa Rica.   The supplier in Costa Rica then ships the parts to Company C (located in USA), where the final assembly will take place.   Who in this scenario, would […]

  • NRI PARTNER ISSUES

    QUESTION: We purchase goods from a non-related foreign party that is acting as a non-resident IOR. The foreign party we purchase from, acting as the non-resident IOR, is not declaring additions to value (tooling that we purchase from them as a separate charge they are not including in their import price).   We have again […]

  • IOR WITH MULTIPLE SUFFIXES

    QUESTION: Our company has one main IOR number with multiple suffixes based on location. I am struggling with internally, each location is treated as a separate company.  Each location used to be separate companies with their own product lines and compliance managers. This is still being maintained this way with personnel and products.  I am […]

  • RIGHT TO MAKE ENTRY

    QUESTION: US company A places a PO to another US company B, who then places a PO on a Foreign Company.   When the foreign company ships to the USA, can EITHER party be the IOR?  I read the CBP right to make entry directive https://www.cbp.gov/sites/default/files/documents/3530-002a_3.pdf, but want to be certain.  It seems like either […]

  • WHO IS THE IOR

    QUESTION: My company issues a purchase order to a USA supplier for a machine.  We eventually pay this USA supplier for the machine. The machine is produced at the USA supplier’s related European factory.  When the machine is shipped, the European factory issues an invoice to the USA supplier.  The bill of lading is consigned […]

  • PARTNERS AS IOR

    QUESTION: Scenario: A company will be entering into a Joint Venture (JV) with 2 other companies on a 40/40/20 split and everything will be procured on the JV documents. The JV owns the material and the JV will make payments to the suppliers, not the individual partners. Questions: Is there a way where the material […]

  • REPORTING IOR ADDRESS CHANGE

    QUESTION: We are changing the address of our corporate headquarters due to the sale of our building.  Can the membership advise what I need to file in order to update customs records? ************** Answers: File a 5106 with CBP. If you have an ACE portal account you can change the address yourself. ************* Reach out […]

  • 3rd PARTY IOR – RELATED PARTY TRANSACTION

    Question:     We are being contracted to only handle the International Freight and Domestic delivery on a machine coming from overseas.  The value of the machine (2 related parties buying direct), will be listed on the CI, as “for customs purposes only” and we will report and pay duty on it.  Does anyone know […]

  • BROKER AS IOR

    Question:   Under the Right to Make Entry Directive, a licensed broker can agree to be the IOR for that Import when asked by a domestic or foreign party or Nominal Consignee. My question, is how does the broker protect himself? Who signs the POA to  the broker: domestic party, foreign party, nominal consignee? *************** […]