QUESTION: How do you file for a liquidation date extension?  We are a self-filer.  ************* Answers: I submitted via email and received a response within a few days. They can extend liquidation for entries pretty fast, even the ones that are very close to liquidating. To request the extension, send an email to the Center […]

  • FDA regulations for face masks

    QUESTION: Our company is considering importing face masks from a related company in China to donate to the medical community.  We plan to use HTS 6307.90.9889 per NY N011568.  Our broker advised the masks will need FDA approval if used for a medical purpose.  We have doubts we will be able to obtain the FDA […]


    QUESTION: I am looking to find out if the N95 Cone respirators are regulated by FDA. These are the face masks to fight out the Coronavirus. ========== Answers: Yes! If being imported for internal use and not resale, you do not need registration but they must come from a registered manufacturer and you will still […]


    QUESTION: My question in general is, will a US company be able to deliver goods to Monomers which is on the DOW JONES SOR List This company is 100% owned by Petroquímica de Venezuela SA, which is 100% owned by the OFAC E.O. 13808 and E.O. 13884 Sanctioned Government of Venezuela. Monómeros Colombo Venezolanos SA […]


    QUESTION: Anyone hearing about a potential closure of the ports of Los Angeles/Long Beach? ========== Answers: The Directors of both Ports have had calls with the trade and have sent out messages that they open, staffed and working. ========== The terminals in Los Angeles and Long Beach are open and operating normally.  Port operations are […]

  • Importing hand sanitizers

    QUESTION: Anyone familiar with importing OTC hand sanitizers? ************ Answers:I’m currently advising clients on this. Hand sanitizer is considered an over the counter (OTC) drug by the FDA. There are rules regarding ingredients and what the labels and marketing can say. I’m a Customs lawyer but am working hand-in-globe with my FDA lawyer partner on […]

  • A “No SLI” policy

    QUESTION: Does anyone in the membership have a “No SLI” policy? My management would prefer that we issue no SLIs, and have our approved customs brokers file EEI and then provide the ITN to the shipper. Do you have a written policy I could see?  “In the event an SLI is requested, please forward request […]


    QUESTION: Taking the definitions of technical data and technology into account, is a bill of material (BOM) consisting of part number, description and quantity considered technical data and/or technology? =========== Answers: My understanding from DDTC is that this is not “technical data.” George Tuttle IIILaw Offices of George R. Tuttle, A.P.C.1100 Larkspur Landing Circle, Suite […]

  • US owned returnable containers disposed of in Mexico – taxes due?

    QUESTION: US company owns returnable containers used to ship product to a customer in Mexico (customer handles the export and import).  The program has ended and the containers are no longer required (obsolete).  The containers are at the customer’s facility in Mexico.  Customer states there would be importation taxes due if they dispose of the […]

  • 5106

    QUESTION: We are trying to understand the 5106 requirement.  If another entity is the importer of record, but we are only the recipient and not otherwise involved in the transaction, are we still required to submit a 5106 form?  A client shipped some of their own materials to us from a foreign location via a […]

  • Textiles, soaps and apparel from Syria

    QUESTION: I am in the “creative” space.  I am artist and in addition to painting I buy, import and export art supplies etc. I was at an event this weekend at which some reps from a large Intl NGO were in attendance.  They were discussing all of the neat artsy, hand made things they were […]


    QUESTION: A US company and a China company sign an agreement to create a joint venture.  At import into the US of finished product built in China using the US know-how transferred to China to make the parts has a Royalty.  The China company will pay the US company a royalty for each part sold […]