Miscellaneous

MISCELLANEOUS

  • RISK ASSESSMENT TEMPLATE

    QUESTION: I am interested to conduct a gap analysis / risk assessment of our trade compliance program.  Can anyone share their SOP, manual etc on this topic?  I understand each trade compliance program is different based on import profile (do you have assists, use SPIs, have new products, new vendors, use an automated system / […]

  • L/C PROCESSING

    QUESTION: Our company uses third party provider for processing our letters of credit.   What are other companies doing in regards to signing original bills of lading (OBL)?   Do you have the third party provider e-signing the OBL’s on behalf of the freight forwarder or does the freight forwarder handle that responsibility directly? ========== […]

  • VISA WITH EXPORT CONTROL CLAUSE

    QUESTION: We are rolling out a trade compliance manual in our organization and we received questions from HR about export controls on visas. My understanding is that the visa itself is sometimes issued with an export control clause and that Form I-129 visas have an export control certification on the application. I was able to […]

  • CEE CF 28 QUESTIONS VIA E-MAIL

    QUESTION: I’m getting e-mails directly from our CEE asking for entry information and NAFTA Verifications, subjects that used to be addressed through issuance of a CF28. Is anyone else getting communication from their CEE this way? ========== Answers: The CEEs do contact importers directly with their requests via email, and no longer use the CF28s […]

  • 5A992c REPORTING REQUIREMENTS

    QUESTION: If an item has been classified by the BIS as a Mass Market item with classification 5A992c, are there are any special reporting requirements for the exporter when shipping the 5A992c item? ************** Answers: I asked the Department of Commerce a similar question: we were provided a mass market classification from the OEM and […]

  • CREDIT AFTER IMPORTATION

    QUESTION: We purchase products from China.  After we ( US company) received several shipments we also received a credit because of the devaluation of the Chinese dollar.  Are we able to reclaim the extra duty paid before we received this credit? **************** Answers: My take is that the revised pricing meets the ‘Price Paid or […]

  • CONSULTING AND CUSTOMS PERMIT

    QUESTION: I am a licensed customs broker.  If I set up a consulting firm to perform consulting services related to customs activities but not clearing shipments and have a company name (and IRS#), do I need to advise customs and apply for a permit? ************** Answers: I too am a licensed broker and have a […]

  • PRODUCT OF VS. MADE IN USA FTC

    QUESTION: Below is my understanding of CoO labeling in regards to the FTC standard. Does anyone in the membership have a different understanding? “Product of USA” and “Made in USA” must meet the “virtually all” standard, and there is no difference between the two. “Assembled in USA” is compliant provided that a substantial transformation occurs […]

  • SUBSIDIARY ENTRY FILING

    QUESTION: We have issued a POA to a broker for our corporate office address which is also tied to our Customs bond. We have several locations in the US that operate with the same Tax Id but different suffixes. We instruct the broker to clear shipments for those locations under the name and address of […]

  • SECTION 321 ENTRIES

    QUESTION: I have a question on entry limits under section 321 procedures/limits.   19 USC 1321 (a) (2) states: “admit articles free of duty and of any tax imposed on or by reason of importation, but the aggregate fair retail value in the country of shipment of articles imported by one person on one day […]

  • CEE COMMUNICATIONS

    QUESTION: I’m getting e-mails directly from our CEE asking for entry information and NAFTA Verifications, subjects that used to be addressed through issuance of a CF28. Is anyone else getting communication from their CEE this way? ========== Answers: Yes.  That’s one of the benefits of a CEE.  No more CF28s all over the place! Direct […]

  • LIFTING OF ZTE SANCTIONS

    QUESTION: We know that the suspension of sanctions against ZTE is due to be lifted/resume on March 29 – unless the court approves the settlement ZTE reached with the government. I can’t find any news of whether the court has yet approved the settlement – has anyone? =========== Answer: https://www.justice.gov/opa/pr/zte-corporation-pleads-guilty-violating-us-sanctions-sending-us-origin-items-iran ===========