Miscellaneous

MISCELLANEOUS

  • Refusal to complete end user certification

    Question: Hello members, I am fairly new to compliance in the aerospace industry. We have a customer that is a major airline that is refusing to complete our End User Certificate form. The PO is for a domestic sale of 9A991 parts. My question is: How would you address this with the customer? Do you […]

  • USITC Investigation Questionnaires (AD/CVD)

    Question: Who is responsible for completing USITC Investigation Questionnaires (AD/CVD) questionnaires within a company? The questions seem to be more related to sales versus import/export related. Answer 1: The party who has the information to be able to answer the questions. Answer 2: Typically I have turned this type of request over to the Finance […]

  • FMS and Commercial Invoice

    Question: In the case of an FMS sale, is the US manufacturer of the defense article required to issue the export commercial invoice or is the invoice issued by the U.S. government. I have a case where a client, the U.S. manufacturer of the defense article is being asked to issue the commercial invoice (request […]

  • Acronyms

    Question: Good morning – can someone tell me where I can find a list of acronyms and the meanings used for Import/Export and Supply Chain ?  Thanks so much, Answer 1: This may be helpful.  https://www.thompsoncoburn.com/docs/default-source/publication-documents/trade-compliance-handbook1-29-20163c302326dda26f05acb8ff0000ba5cc9.pdf?sfvrsn=1e924cea_31  Answered by: Robert Shapiro – rshapiro@thompsoncoburn.comTitle: Partner, Company: Thompson Coburn LLP

  • NON-US PERSONS PROVIDING HTS SERVICES

    QUESTION: From this week’s Federal Register Notice, “CBP has clarified in Headquarters ruling H045695 (October 15, 2010) that classification at the six digit HTSUS level does not constitute customs business. In addition, classification at a level lower than six digits, such as the four-digit HTSUS level, is not considered customs business either. Even though CBP […]

  • UFLPA

    QUESTION: What happened to those Poly silica shipment that got stop due to UFLPA?  If they were released, what documentation is needed to release them? *************** Answers: Information on detained shipments under WROs or UFLPA is not being formally released by CBP, although informationally there is no polysilicon being released for entry if the importer […]

  • Documents with carrier

    QUESTION: It’s been some time since I’ve been involved in preparing documentation for an export shipment.  With that said, many years ago we sent all invoices and documentation electronically to a customer’s broker instead of with the truck carrier.   Upon joining my newest company, I’ve been told all documents are sent WITH the physical shipment […]

  • Definition of Agent in intermediate consignee 15 CFR 30.6(b)(2)

    QUESTION: Can anyone tell me the definition of “agent” in the context of 15 CFR § 30.6(b)(2) Intermediate Consignee?  Would an agent be a buying or selling agent, distributor, export agent?  What is the role of an agent? 15 CFR § 30.6(b)(2) Intermediate Consignee – The name and address of the intermediate consignee (if any) shall be reported. The intermediate […]

  • NON-US PERSONS PROVIDING HTS SERVICES

    QUESTION: From this week’s Federal Register Notice, “CBP has clarified in Headquarters ruling H045695 (October 15, 2010) that classification at the six digit HTSUS level does not constitute customs business. In addition, classification at a level lower than six digits, such as the four-digit HTSUS level, is not considered customs business either. Even though CBP […]

  • CUSTOMS ENTRY AUDIT CHECKLIST

    QUESTION: Our company is now bringing customs compliance in-house, and we are aware that the rule of thumb is to audit approx. 10 – 12% of our entries. I would like to set up a good cadence for monthly audits, but can’t seem to find a good template/checklist. Would any members possibly have an audit […]

  • 5106 Address Change

    We recently sold off several of our U.S. entities. I asked the Customs broker (the same broker will still be used) to transmit a 5106 change to the new address. All but one went through. The one that did not go through came back with a message that the importer# (the EIN) is frozen and […]

  • SUBJECT TO US TARIFFS

    Players: Company A – USA            Seller Company B – China         Vendor producing product for Company A Company C – Canada      Buyer, IOR Scenario: A takes the order from C,  product is made by B Product is shipped directly from B to C                 The product does not cross US border. Question: Who pays Canadian Tariff; […]