Miscellaneous

MISCELLANEOUS

  • INTERNAL COO VERIFICATIONS

    QUESTION: Does anyone in the membership have instructions for internal COO verification they would be willing to share? ========== There are various methods that can be utilized depending on the merchandise. Our company procures many manufactured items from around the world.  Most of our equipment is fairly easy to confirm through a brief read of […]

  • ERP CONTROLLED PRODUCT IDENTIFICATION

    QUESTION: How does the membership identify controlled products within their ERP system whether classified under ITAR or on the CCL? =================== ANSWER: Depends on the ERP. Many ERP lack adequate functionality to support Customs/Compliance (Import/Export) work.  The area is, as everyone who does this knows, quite intricate and even complex. Even where the ERP does […]

  • CURRENCY CONVERSION PROCESS

    QUESTION: I am having difference of opinion with our corporate office concerning the value reported for export and currency conversion. Corporate would like to issue one conversion chart to be used to determine value to be reported for export per year. As currency rates fluctuate regularly, my point is we need to be using the […]

  • CERT OF ORIGIN CONFIDENTIALITY

    QUESTION: My company wants to arrange a shipment from foreign country A to foreign country B.  The customer in foreign country B will want to receive a certificate of origin, but we don’t want the name/address of the manufacturer in country A to appear on the certificate.  How can we make this happen?  Most templates […]

  • CONTROLLED ARTICLE BLOCKS

    QUESTION: I am a novice to ERP systems, and was wondering if the membership could advise on whether their SAP or other ERP systems assist or has the mechanism to notify of a block due to an article being controlled?  Does an ERP system have this capability or would this be additional software or additional […]

  • FREIGHT AS A PROFIT

    QUESTION: I have freight as part of my import/export compliance responsibilities and I am NOT knowledgeable in this area at all so I am looking for feedback on a situation.   I have learned that we do not pass on our discounted rates when quoting customers (i.e. 22 lb. box to Chile via express courier […]

  • CONFIDENTIAL MANIFESTING

    QUESTION: We are wondering if any of the members have applied for the Confidential Manifest with CBP. Are there any other benefits beside from preventing information on import activities from being disclosed to the public? Is there a specific requests form from CBP for importer to fill out? Do we have to input all the […]

  • CUSTOMS ON-SITE SOP

    QUESTION: Does any in the membership have a SOP they would be willing to share for when CBP comes to their facilities? ========== Answer: Please see attached: http://www.icpainc.org/wp-content/uploads/2014/10/visit.docx  

  • TAA ELIGIBILITY CLAIMS

    QUESTION: Although it does reside within Title 19 for Customs, does CBP in practice enforce TAA eligibility claims made to the US government in domestic US sales, or is it more likely to be another agency such as GAO? ========== Answers: Numerous rulings by Customs on TAA eligibility place the determination within Customs. Some Customs […]

  • MID CODE

    QUESTION: I have been reviewing my ACE reports as part of an audit process and came across an issue. One of our brokers is using our company address as the basis for MID on the CF7501 whenever; we have our manufactured product (non-textile, non-apparel) being returned from foreign customers for repair and return. I have […]

  • SUDAN

      QUESTION: With Obama’s executive order in January, is it time to drop reference to Sudan in the current standard litany of “five bad countries” of Iran, Cuba, Sudan, North Korea and Syria (leaving aside here Russian occupied parts of Ukraine)? (Also putting aside the few very specific sanctions related to Darfur or South Sudan) […]

  • RUSSIAN 50% OWNERSHIP SCREENING

    QUESTION: I was wondering if anyone in the membership are using a Ownership Questionnaire for the purpose of exercising due diligence in screening potential new Russian customers under the current 50% ownership rule?  If so, have you had much luck in receiving valid questionnaire responses, or do they just leave you with more questions? Also, […]