Miscellaneous

MISCELLANEOUS

  • 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 ( […]

  • Articles made in Taiwan

    QUESTION: I cannot locate any CBP publications that state whether articles made in Taiwan and imported into the US should be labeled with country of origin of:  “Taiwan” or “Taiwan R.O.C.” . Does anyone know what is definitively required? ************** Answers: For U.S. import, there was recently a change to the marking requirements for Hong […]

  • INCANDESCENT BULBS

    QUESTION: Is anyone aware upcoming elimination of incandescent bulbs and if so, do you have any information regarding this? ========== Answer: Go here:  https://www.epa.gov/mercury/how-energy-independence-and-security-act-2007-affects-light-bulbs https://www.cnbc.com/2022/04/26/biden-blocks-sales-of-inefficient-lightbulbs-reversing-trump-policy-.html The new reinstated rules are here:  https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=4 George Tuttle IIILaw Offices of George R. Tuttle, A.P.C.3950 Civic Center Drive, Ste 310 San Rafael, CA 94903 **Please note our new address […]

  • TSU VERSUS NEED FOR TECHNOLOGY LINE ON LICENSE

    QUESTION: Does anyone know where I can find some good regulatory guidance on the following: Company A is exporting under a BIS license a replacement CPU for ECCN 9A610.f Military Aircraft Ground Support Equipment. Company A plans to send engineers to the foreign customers onsite facility to remove the defective CPU and install the replacement. […]

  • Russia Parallel Import List

    QUESTION: Does anyone in the membership have an English language copy they can share of the list of products approved for parallel import which was published by the Russian Ministry of Industry on May 6, 2022? %%%%%%%%%% ANSWER: The document contains 25 pages with over 50 groups of commodities included in that list. The Ministry […]

  • Russian Sanctions

    QUESTION: Does any know where to find all current US sanctions against Russia?  Question is being raised by our sales if our EU distribution can still sell to a new customer there. %%%%%%%%%% ANSWERS: The simplicity of your question suggests you may not be aware of the complexity of the answer. There are financial sanctions and […]

  • Filing letter of intent for actual use

    QUESTION: 19 CFR 10.134 (Declaration of Intent) states, in part, that a showing of intent by the importer as to the actual use of imported merchandise shall be made by filing with the entry a declaration as to the intended use of the merchandise.  How would such a declaration of intent be “filed with the […]

  • ITALY CONSUMPTION AN EXCISE TAXES

    QUESTION: Is anyone willing to share if you have successfully obtained consumption and excise taxes exemption in Italy for your products? Or your struggle on obtaining one? **************** Answer: Any VAT exemption would be contingent on the type of product you are selling and also if your company is established in Italy or another EU country. […]

  • MANIFEST DATA ACCURAC

    QUESTION: A current supplier of ours has seen recently on a manifest data site that our company is buying from their competitor which is not the case.  The manifest data shows the supplier (which we have not purchased from in over 3 years) shipping the goods to our Canadian location through the port Tacoma. Needless […]

  • SCREENING GENERIC CUSTOMER NAMES

    QUESTION: We have a new inquiry from a potential new customer in Venezuela.  I screened them and nothing comes up on the denied parties list or online. The company name begins with a generic name “Comercializadora….” Which means “marketer”. I believe “Comercializadora” means they import for a bunch of different companies/end users.   Many government entities […]