Miscellaneous

MISCELLANEOUS

  • JOINING A CEE

    QUESTION: How does an importer register/sign-up under a CBP CEE (Center of Excellence and Expertise)? ========== Now that the CEEs are fully activated, you don’t have to sign up. You are already in it! Sign up was required during the pilot, but now CEEs are managing entries in their area of expertise as a matter […]

  • DIRECT BOOKING OF FCL

    QUESTION: Our company is going direct to steamship lines when booking our FCL, and no longer using an NVOCC.   The question has come up on how to handle our LCL and consolidations directly with a steamship line without using the services of an NVOCC.   Question 1 , if we have a consol shipment […]

  • T.D. 91-7

    QUESTION: Can anyone in the membership please provide a copy of TD 91-7? ========== Answer: Here it is  . . .  again.   George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 Direct: (415) 288-0428 Cell: 254-5986 Firm: (415) 986-8780 Fax: (415) 986-0908 Email: geo@tuttlelaw.com […]

  • SCH B DESCRIPTION ON SHIPPING INVOICES

    QUESTION: Historically, we’ve always only included the Schedule B Number on Customs Invoices for shipments being Exported from the U.S. However, recently, there’s been push-back from our plants that we also need to include the Schedule B Description on the Customs Invoices.  They need this to enter it into an express courier’s system when they’re […]

  • INTERNAL TRAINING METHODS

    QUESTION: We have a good trade compliance training and education program in my company but we plan to re-imagine it to make it even better.  Do any members have any unique or outside-the-box training preparation and delivery methods that you’ve found to be effective?  Especially when dealing with different cultures where English is a second […]

  • M&A SCENARIO

    QUESTION: I would like to check with the membership on liability of acquisitions.  Our company recently acquired two companies, these 2 companies had subsidiaries in foreign countries.  We purchased the U.S. corporate entities but not its foreign subsidiaries.  My question, do we have any liability for its foreign subsidiaries should there any violations happened prior […]

  • FCPA RESPONSIBILITY

    QUESTION: Where does the responsibility for FCPA (Foreign Corrupt Practices Act) reside in your organization?  Does your Global Trade Compliance/Customs Compliance department or team manage the compliance for this area?  If not, how is it managed and by ‘whom’? ==================== ANSWERS: In my experience, FCPA is usually managed by Legal and not Trade Compliance when […]

  • VALUATION PSC

    QUESTION: We understand that PSCs with a revenue adjustment of less than $ 20.00 are not required. We import under a preferential trade program and have discovered potential issues with our valuation. There will be zero duty impact with making value corrections so we are clearly under $ 20.00/entry. I would think to cover ourselves […]

  • USED EQUIPMENT IMPORT EXPORT

    QUESTION: We are importing an used equipment and will extract one part from it,  This part will be then exported back to the same foreign supplier in France.  Is this  considered a substantial transformation?  We are no charging the supplier for the work perform to break the equipment apart and obtain the part.  I am […]

  • ROUTED TRANSACTIONS

    QUESTION: I am hoping some guidance can be given for Routed Transactions, and what others consider to be due diligence for attempting to have corrections made to EEI filings (all EAR99 products).   The error could be the USPPI address, or adding Inc or LLC to an entity name, or not placing the correct gross […]

  • MTB PETITIONS

    QUESTION: If another company requests and is granted reduced duty on a tariff code / item, can any importer also claim the reduced duty for the same goods?  If so, what is the procedure? ************** Answers: Yes, any importer can take advantage of a MTB if it is granted.  The MTB will be effective for […]

  • MANAGING MANIFEST CONFIDENTIALITY

    QUESTION: Regarding Manifest Confidentiality, I am requesting clarification regarding the variations of company information that should be included. I have looked at past answers on this topic which include how the request is worded. I realize that including variations of the actual names of the parties (importer/consignee) in the request are key to effectively keep […]