Miscellaneous

MISCELLANEOUS

  • Volume Discounts and Penalties

    QUESTION: My company is looking to enter an agreement with a foreign vendor where we would pay a discounted value post purchasing a minimum agreed volume of product, but if we do not purchase the minimum agreed volume of product, we will pay penalty.  My thinking is that we would use invoice transaction value as […]

  • Custom Brokerage Exam Prep (April 2019 Exam Answer Explanation)

    QUESTION: I am preparing for the 2021 April Customs Brokerage Exam and am currently taking previous exam as practice.  Question #47, from the April 2019 Exam, in the Practical Exercise section has me lost.  A commercial invoice is given to answer 5 questions, with no other instruction or information.  Follow the link April 2019 Exam […]

  • Certificate of Origin

    QUESTION: Scenario: My organization is a chemical manufacture and recently imported US product (USMCA Inventory) to a leased facility as a related transaction. From this facility the inventory is then sold as a domestic transaction within Canada. We cannot guarantee our product is not combined with non-originating inventory at facility. The Canadian customer is now […]

  • PRODUCT STANDARD DETERMINATIONS (UL, CE, NOM, etc.)

    QUESTION: Can anyone share with me where the role of ensuring a product meets UL, CE, MX NOM or any other country specific OGA requirement for safety or standards (Cert of Conformity) lies in your company? I realize these things impact the ability of a company to import into a country but to me these […]

  • VENDOR CHANGE AND SKU ID

    QUESTION: From a C-TPAT and/or General Customs Compliance standpoint, would there be any compliance issue if…  – one of our vendors changed from X (who used Manufacturer C) to Y, – the new vendor Y kept the same Manufacturer C and the Importer of Record kept the same Stock Keeping Unit (SKU) Number for Manufacturer C?  […]

  • WHEN TO TRANSACTIONALLY SCREEN FOR RPL

    QUESTION: In talking with our project management team the discussion for best practices for screening new potential customers in the US came up. I believe best practice is screening before you even contact the company.  My PM asked where an infraction could occur if the quote was presented to the customer due to insufficient screening, […]

  • Citations

    QUESTION: Asking the membership for their assistance in specific citations that enumerate what is required .vs. what is nice to have. Commercial Invoice Packing List SED ========== Answers: For imports see  19 CFR § 141.86 ========== For Items that are controlled. New rules Effective Nov. 15, 2016 as part of the President’s Export Control Reform (ECR) […]

  • Importing Company-Owned U.S. Goods Returning

    QUESTION: I’m fairly new to my position (as our company’s EO) and I’m not convinced the company’s process of re-importing our company’s ITAR/CCL/USML items is correct. I’m therefore attempting to ensure our regulatory ducks are in a row. We file for our own export licenses, file via ACE prior to shipping export-controlled parts/equipment, and we […]

  • Arrival charges

    QUESTION: Who is ultimately responsible for the arrival (ocean) port charges when the Incoterms denote the vendor is responsible for the freight to an inland destination, such as DAP Laredo TX?   My understanding is that any original destination ocean port charges should be paid by the Vendor where the agreed upon Incoterms are DAP […]

  • Hand Sanitizer Destruction

    QUESTION: FDA has hand sanitizers in California that have been refused entry. We need to destroy them, but are being advised that we cannot in California. Does anyone know what states allow will allow destruction of hand sanitizers? %%%%%%%%%% ANSWER: Is the FDA requiring destruction only or can you export them instead?  If you are […]

  • UK HTS

    QUESTION: Can anyone verify the correct UK website for their “new” HTS codes since Brexit? %%%%%%%%%% ANSWERS; We, in the US, are still using this site and our offices in England and Aberdeen advise it is the correct one to use post Brexit: https://www.trade-tariff.service.gov.uk/sections The Online Trade Tariff: Look up commodity codes, import duty, VAT […]

  • Dangerous Goods vs Hazmat

    QUESTION: What is the difference Dangerous goods and Hazmat?  For example: Shipping Li-ion batteries UN3481 PI967 II – is not considered DG.  Can someone help explain why this will not be considered a DG shipment?  %%%%%%%%%% ANSWERS: Technical Instructions for the Safe Transportation of Dangerous Goods by Air and the UN model regulations: “Dangerous goods are […]