Miscellaneous

MISCELLANEOUS

  • TYING MILESTONE PAYMENTS TO INDIVIDUAL SHIPMENTS

    QUESTION: This customs valuation question is directed to importers or exporters that build large scale equipment and systems with milestones and milestone payments. We contract with an unrelated OEM to build a system of equipment and machinery for us that has one overall function and purpose.  The system is comprised of several different pieces of […]

  • LICENSE EXCEPTION STA

    QUESTION: Can someone clarify or define § 740.20(b)(3)(ii)(C) of the EAR for me? Does this qualify for holding items for demonstration purposes in A:5 countries?  ========== Answers: § 740.20(b)(3)(ii)(C) makes clear that in order to use license exception STA (Strategic Trade Authorization) all parties to the transaction must have been approved on some prior export […]

  • BIS RUSSIA MAY 09th ADDITIONS

    QUESTION: One of our products has appeared in the May 9th Federal Register notice regarding exports to Russia.  We cannot export without a license, and a policy of denial is in force Are we to conclude that we must also cease with our export of information in the form of technology, product support, etc…. because […]

  • IRAN N.KOREA AND SYRIA NON-PROF. ACT SANCTIONS

    I have a question about the INKSNA-   (Iran, North Korea, and Syria Non-Proliferation Act Sanctions) Where is this thing codified?   I’ve “googled” liked there’s no tomorrow and the only thing I can find are State Department references indicating new parties have been added to the list.    There are also many notices in the Federal Register […]

  • 123.4 TEMP EXEMPTION

    QUESTION: When the 123.4a1 exemption is being used, does the part and parties all need to be on a previously approved license? When we review the requirements listed in 123.4c, it does not say a previous approved license is required.  It says, (c)(2)” At the time of export, the ultimate consignee named on the Electronic […]

  • ITEMS WITH ENCRYPTION REMOVED

    QUESTION: I have a couple of questions regarding encryption controls.  We have a piece of equipment, a router, listed on the OEM website with ECCN 5A002A1 740.174(b)(2) because of the encryption, but our customer is telling us that they removed all encryption from the device. Does this then mean that regardless of OEM website, the router […]

  • DROP SHIP RESPONSIBILITIES

    QUESTION: I have an example transaction where I am having a hard time defining who is responsible for the importation of a shipment and could use some advice from the Community. We place a purchase order to a domestic supplier under FCA Incoterms with no defined destination as our ERP system is not set up, […]

  • ICPA Fall Scholarship time!

    It’s time for our annual Fall Scholarship program.  The ICPA scholarship is available for regular (non-service provider) paid members of the organization and any unmarried dependent children of the member under 25 years of age.  The deadline for the completed application & essay is noon/CST on July 15, 2022.  Please read and follow the instructions […]

  • IMPORTING DRUG NOT APPROVED IN US

    QUESTION: What permits / considerations are required to ship a commercial veterinarian drug product to the US for in vivo research if that drug is not approved for use in the US? ========== Answer: This link may be a good starting point for you Importing – Veterinary Drugs https://www.fda.gov/animal-veterinary/import-exports/importing-veterinary-drugs Add’l Answer: You generally want to […]

  • Threat assessment

    QUESTION: I’m looking to beef up our risk assessment procedures as part of CTPAT membership. Would anyone be willing to share the information they use to help conduct the threat assessment portion of the 5-step risk assessments? ****************** Answers: You can use, www.cia.gov  Alejandra Madrigal Director, Global Trade Compliance & Logistics Solutions Address: 256 Post Road […]

  • Terms of sale

    Is there a different term that we could be purchasing under that covers the transfer of risk at the same level, so our customs broker does not deduct these fees from the entered value? Simply advising them not to deduct the charges may not work effectively…. *********** Answers: Try FOB  ************ The reason your broker […]

  • ECCN number for PCB evaluation board ( printed circuit assembly)

    QUESTION: Does ECCN apply to PCB evaluation board ( without software) designed to change the channels of optical transceivers ? I went through category 5 : ECCN for optical transceivers is 5A991 ( sold separately) Couldn’t determine / find anything related to the basic printed circuit assembly evaluation board to be used for programming ( […]