• COO of non substantially transformed goods

    QUESTION: How are other companies marking their commercial invoices for imports to the US from Mexico to communicate COO for Section 301 purposes when general COO = MX but Section 301 = CN? ============ Answer: The Energizer case already has the answer.  Distilled, however, it’s a China origin with regards to Section 301, but it’s […]

  • Drop-Drop ship into Canada

    QUESTION: We are a US company(A).  Our supplier is a Chinese company(B).  Our customer is a US company (C).  The end customer(C’s customer) is in Canada. (D). Sales would like to ship directly from our Chinese supplier(B)  to our customer’s customer(D) who is located in Canada.  The plan is to bring the goods from China […]

  • Invoice for customs purposes only

    QUESTION: I just completed some internal auditing that we do quarterly.  The entry I audited had two entry line items, but when confirming how much was actually paid to the foreign vendor, to confirm that the price paid was in fact the same as the price declared on the 7501, only one line item was […]


    QUESTION: My customs broker has informed me of a late entry summary filing that was their error, and indicated that CBP may fine us as the IOR. (filed one week late) What is the proper next step for us as the IOR? Notify CBP or wait for the penalty notice? What is the potential penalty? […]


    QUESTION: I am working to create an at-a-glance document to help explain internally to our global stakeholders who all the U.S. government entities are that issue the denied/restricted/sanction lists, what their reach is, and what the implication of the lists are.  Probably more than the one page high level document that I envision, but I […]

  • EIDR and CFSP Application in the UK

    QUESTION: Looking for help from the membership. We are in the process of submitting our EIDR and CFSP application (Simplified Procedures) for our imports into the UK now that we finally received our DAN.  Part of the application process looks to be the need to submit written procedures on the following: Written procedures You must […]

  • MID-Codes: buying directly AND indirectly from same MFG

    QUESTION: An importer buys directly from a Manufacturer (XYZ) AND indirectly through a 3rd party Vendor who has partial ownership in the same MFG (ABC) from the same Manufacturer:  should there be 2 separate MID-codes??…  – For the Direct Buy:  one Mid-Code based on the Manufacturer name as (XYZ) AND  – For the Indirect Buy:  […]


    QUESTION: I ran across an anomaly in the tariff recently relative to heading 8303.  The HTSUS differs from the Harmonized System Convention. • HTSUS: Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the    like, AND PARTS THEREOF, of base metal. • HS: 83.03   Armoured or […]


    QUESTION: I’m tired of filling out so many different formats of SLI. Does anyone have a sample general one, maybe in Excel, that I could customize for my company? ************** Answers: Attached .pdf and .doc formats. https://www.icpainc.org/wp-content/uploads/2021/03/ICPA-shipper_export_dec.pdf https://www.icpainc.org/wp-content/uploads/2021/03/ICPA-SED-form.doc **************** The NCBFAA has an industry standard SLI posted at its website.  Either search on “NCBFAA SLI” […]


    QUESTION: Can anyone in the membership share a sample contract clause addressing title transfer at a (named) longitude and latitude location in the ocean? ***************** Answers: I think you need much more than just a contractual agreement, you need to address issues around the ocean negotiable B/L for example as this is considered the title to […]

  • Practical Work Experience Import/Export Field

    QUESTION: Looking for advice from the membership about how to obtain work experience in the import/export industry and best method(s) to approach a potential career move. I’ve spent the last 5+ yrs. attaining the broker license, attending workshops & courses to learn/hone classification skills, NCBFAA CES, etc. Yet, when perusing job openings and calculating my […]

  • Use of SPI C#

    QUESTION: Taking into account CSMS 14-000077, we understand that goods entered under Civil Aircraft Agreement that are marked or eligible to be marked the “product of” a country (let’s say Mexico in this case) with which the U.S. has an FTA that provides MPF exemption (let’s say USMCA in this case), can be imported free […]