Miscellaneous

QUESTION: Based on OFAC 50 Percent Rule, can you share how your companies handle the screening of partners to meet the aggregate requirement?   How do you manage the screening and aggregate requirement on cases where one entity is owned by, sometimes, hundreds of persons? ========== Answers: You have to do the research, or more […]

QUESTION: When determining country of origin can the injection of software and programming of a device constitute a substantial transformation? We are looking at importing a contactless NFC card reader manufactured and assembled in Germany. This device falls under HTS of 8471.90.0000. This reader, however, has only the basic firmware programmed into it and until […]

QUESTION: Our parent company in Japan sends shipments DDP shipments to a  my company, a related division in the United States. They then ask that we be importer of record, classify the parts and manage the clearance of the shipment.   The costs for duty and clearance are transferred to us from the parent company. […]

QUESTION:   Has Israel settled what their NLR designation is going to be?   Obviously it can’t be EAR99, so do Israeli export filings just say “NLR” or what?   ==========   Answers:   EAR99 and NLR are not mutually exclusive. EAR99 only addresses what the item is, and has no bearing on where it’s […]

QUESTION: Can anyone share a chart that provides descriptions of what the various column headers/item names in ITRAC refer to, or does anyone know where to obtain this information? For example, in the “SENSE_US” table, what do the column headers “User_Fee_L1,” “User_Fee_L2,” and “User_Fee_L3” refer to?  Specifically, we’re trying to identify MPF and HMF paid […]

QUESTION: Does anyone have history with using CBP Form 4455s? We service the oil and gas industry and used to be able to file 4455s with local Customs for goods going out onboard the construction vessels for use in the Gulf of Mexico. The goods would then be signed off once the vessel returned and the goods […]

QUESTION:   I’m curious as to whether any members have experience in dealing with the new Australian Biosecurity Act 2015 and Biosecurity Regulations 2016 – specifically regarding the new BICON site and import permit conditions.   We ship laboratory reagents and low-risk genetic material to Australia and it seems these new regulations and procedures will […]

QUESTION: Does anyone know where to locate the current list of countries that are not eligible for option 4 Post Departure filing in AES? ======================== ANSWER: See section 4.75(c) of the customs regulations.   http://www.ecfr.gov/cgi-bin/text-idx?SID=3139c8d5f211ce336c7ba5d9e08346bb&mc=true&node=se19.1.4_175&rgn=div8   George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 […]

QUESTION: We plan on importing an unassembled good that is divided between two boxes.  This item will always be shipped/imported, warehoused and eventually sold that way. Our warehouse manager is insisting that we set this item up as two separate item numbers for inventory purposes and therefore, we must purchase under two separate item numbers […]

QUESTION: For Netherlands imports, in which NL importer is paying a dutiable royalty payment, is there a NL disclosure program for year-end royalty payments or must each shipment include an estimated royalty and  then year-end adjustments made if needed? ========== Answers: Per our Netherlands Office: It is possible to add royalties per shipment or pay […]

QUESTION: If suppliers and customers do not want the list of countries included in our requirements how do we reference embargoed countries and countries subject to U.S. and European Union economic sanctions? Is there a single resource or website to require? ========== Answer: I am not aware of a single website for both U.S. and […]