QUESTION: With the new EEI filing requirement for all shipments to CN, VE and RU regardless of value, I’d like to know if anyone in the membership has knowledge that the main small pack express carriers have had their shipping software updated to accommodate the new export filing requirement where it will raise a flag […]

  • Licensing Question

    QUESTION: Can a foreign entity apply using BIS Snap-R website for a US export or re-export license ? where in many cases, BIS require attach drawing or technical specification of controlled items, can be considerate a deemed export? =========== Answers: Anyone can submit the application, but they must be in the United States at the time a […]

  • “Put Up in forms or packings for retail sale” Question

    QUESTION: If an HTS specifically says “put up in forms or packings for retail sale” can you only use that HTS when it will be sold at retail?  Or is it more referring to the format? For example, if our company is importing an item for our own use but it’s the same packaging format […]

  • FF using different name, address and USPPI ID

    QUESTION: What are the ramifications if a company has a Freight Forwarder that is exporting goods for a company but the USPPI ID does not equal the USPPI name and/or the address?   I’m would assume these are all routed transactions but they are not all flagged that way in the AES-202 report. %%%%%%%%%% ANSWERS: Unclear […]

  • Checklist for sales

    QUESTION: Would anyone in the membership be willing to share a checklist for a sales team that would uncover any potential customs or logistics issues a product might have before the fist order is placed that wouldn’t be surfaced for other processes. Looking for a something general .  Some of the items would be lighting […]

  • Customer Disclosure: Notification Requirements

    QUESTION: We have been notified by a customer that they had a Cyber security breach and some of our data has been involved. They have provided us with a BIS case number, but no details regarding which data was compromised or to whom it was released. Is there a legal requirement for the customer to […]

  • Test Plan Technical Data

    QUESTION: Is a Test Plan that is required for testing and includes specific instructions for an End-Item enumerated in the ITAR considered technical data. ========== Answers: Since you are providing a defense service, per section 120.9 (testing),  you are handling technical data, per 120.10 (definition of what is considered technical data). In short, the answer […]

  • Producer COO certificates

    QUESTION: If you have a generic COO certificate stating that your vendor produced a product in the US, CA or MX but it’s not on a USMCA form, can you use that COO to justify that product qualifies for USMCA or is considered originating material for USMCA analysis of your part? =========== Answers: A good […]


    QUESTION: We have a four party transaction.  Manufacturer A (US) Sells to Related Company B (EU) who sells to Company C (EU) who sells to Ultimate Consignee D (ME). The forwarder is arranged by Company C.  As the only US party, we understand that we are the USPPI and that our sales price  to Company […]


    QUESTION: Regarding the Section 301 tariff exclusions for “Face masks and particulate facepiece respirators, of textile fabrics (described in statistical reporting number 6307.90.9889)” – Does this included reusable face masks? =========== Answers: Yes. This is the HTS we are using. =========== 6307.90.9889 includes all textile face masks. =========== Add’l Answer: Exclusions regard SINGLE USE ONLY  […]


    QUESTION: How do others manage returnable containers/dunnage on their invoices/manifests/entries when they are filled with parts? In recent discussions with an Import Specialist we’ve been advised that every shipment needs to show the returnable containers and an associated value under 9803.00.50/Duty Free – Plastic Containers, IIT, Instrument of International Trade. In my experience, the containers/dunnage were […]

  • Restricted party screening of foreign service vendors

    QUESTION: For those in trade compliance at global companies, you probably screen suppliers of merchandise/materials in addition to customers of your products and/or services. Do you also screen the myriad variety of service providers that you have around the world, such as, to cite a random example, vendors of cleaning services for your company-owned stores […]