• Peru Customs Law

    QUESTION: US company temporary exports widgets to customer in Peru. Customer in Peru exports widgets back to US company after temporary use in country. Looking for the Peruvian Customs Law that cites a commercial invoice cannot be used as proof that the widgets left Peru. Other info: Peru temporary imports are electronically recorded on the […]

  • New to OFAC list

    QUESTION: We currently import from a company in China that was just put on the OFAC list for selling information to Venezuela.  Does this mean we can no longer import from this company? We are not allowed to transact business with them?  I can understand we can no longer export without a license but how […]


    QUESTION: I was wondering if anyone could share a list of commonly overlooked, everyday, items that companies export that require an ECCN with the ICPA community.   I am thinking more along the lines of pharmaceutical and food processing machines and their parts – valves, mixers, motors, hoses, testing machines. like mass spectrometers, turbidimeters, penetrometers, instruments […]


    QUESTION: Is anyone in the membership willing to share any forms used to solicit COO information from vendors? This would also include vendors validating parts that qualify for USMCA. ***************** Answers: We send the attached two forms to our suppliers when requesting country of origin information. We include instructions to use the USMCA form for parts […]

  • 9A604.x versus USML category IV or EAR99

    QUESTION: The drawing from my customer states that the parts and components I am selling to them are controlled by the CCL.  Is that sufficient to classify in the CCL given the fact that my customer is a renowned manufacturer of ITAR products and has classified the items on the drawings they provided? My parts […]


    QUESTION: What is the best practice for commercial invoices to show free product? We are selling product to our customer and providing samples free to charge to assist with subsequent re-sale. The customer is paying off a Letter of Credit (LOC). In order for our customer to get the LOC from the bank, we need […]


    QUESTION: U.S.-based Company X is producing a product with an international manufacturing supply chain. In the manufacture, one step is done in Europe by Manufacturer 1.  Manufacturer 1 exports the material to Manufacturer 2 in the U.S.  Company X acts as the IOR. Manufacturer 2 performs an additional manufacturing step. This material is then exported […]

  • Selling cloud services to Huawei

    QUESTION: I have some cloud analytics services I would like to sell to Huawei.  I am a US company.  Can I even call Huawei? =========== Answer: First you need to understand if what you are selling is subject to the EAR. Next you need to read the Foreign Direct Product Rule to determine if your […]

  • Customs Clearance

    QUESTION: If our company (Company 1) purchased another company (Company 2) that still has its own IOR number, can our company clear for Company 2 even though we do not have a sales agreement with Company 2? Company 2 is considered a to be a division of our company. =========== Answers: You cannot transact customs […]


    QUESTION: We have several customers that do not want the COO listed on the customs documents we provide for export. They do however require a certificate of origin that would include multiple countries of origin.  It is my understanding all invoicing should have country of origin listed for each part purchased regardless of the country it is […]


    QUESTION: Does anyone have any experience with the process to update a statistical note to the HTS? =========== Answer: It depends on what you want to do, but you would start with a submission or request to the appropriate Tariff Affairs Branch of the U.S. International Trade Commission (https://www.usitc.gov/offices/tata) explaining why a modification of the […]

  • DDTC registration

    QUESTION: I am wondering whether we need to look into DDTC registration.  Here’s our potential scenario:                                                                                                                                                                             We are not developing a product to sell into the defense industry, our product is strictly COTS (Commercially- available off the shelf). Our partner we may work with is asking us to sign an attestation form and access a […]