Miscellaneous

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 […]

QUESTION: My question if for those of you out here who are part of a large company (hundreds of customers). Do any of you have issues with obtaining POA’s from the FPPI’s in order to file AES? If so, what steps have you taken to secure the POA’s if any? Have you resorted to other […]

QUESTION: I have a small shipment for a customer that is going to India under CIP terms (CIP Mumbai Airport). I understand that under these terms, my responsibility for everything up to the Mumbai airport, but I am not sure how to ship this package directly to the airport. In this situation, should the customer provide contact […]

QUESTION:   Has anyone ever mapped the Wassenaar List for Dual Use to the EU Dual Use List? I noticed that Category 0 is different, but does the rest map directly one for one? *************** Answers: Response – The majority of dual use lists include the EU Dual Use List are based on the Wassenaar […]

QUESTION: As a US Defense Contractor we screen all successful job applicants when hired.   Should we let applicants know they will be screened as a part of our application process with a statement on our application? Something similar to: XXXXXX  is U.S. Defense Contractor, as such; we screen all successful applicants against the restrictive parties […]

QUESTION: What are you doing to prepare for the arrival of Israel export controls? It’s our understanding that they’re coming and we’re told they’ll be more stringent than the US – though that’s all conjecture at this point. ************** Answers: Israel already has a robust export control program.  Just as the U.S. has two agencies […]

QUESTION: I am trying my best to interpret the OFAC sanctions for Crimea, but I’m no lawyer! Is anyone familiar with the sanctions; if so, is this a correct statement? U.S. persons whether or not operating in the U.S. may not transact or export goods, technology or services to or from the Crimea region of […]