QUESTION: My challenge is to estimate the total potential cost for a prior disclosure scenario, which of course would include: duties, fees and interest for liquidated entries. I have US CBP guidance information regarding prior disclosures requirements and applicable interest rates, but no interest calculation method: no formulas or time periods. Please tell me what calculation method […]
QUESTION: What is the process to transfer an import from a broker’s bond to an importer’s bond after entry? ================ ANSWERS: File a CBP form 3347 within 90 days of entry date. ==================== Bond transfers are explained in 19 CFR 141.20 141.20 Actual owner’s declaration and superseding bond of actual owner. (a) Filing – (1) […]
QUESTION: Under FCA terms, should the seller provide VGM to the buyer? Or to the carrier? I have been asked if we (seller) are responsible to provide VGM data on export shipments via ocean under FCA terms. It seems debatable because, as a supplier, we are not party to the B/L & certainly are not […]
QUESTION: Is there anyone from the Trade community that can provide any advice in whether or not a United States legal entity that is the NRI (Non Resident Importer) in Europe can apply for AEO? US entity has no permanent establishment in Europe only an office with call center and sales but all import / […]
QUESTION: I have a US product that is sent to China for further processing. The country or origin remains the US as the processing wasn’t enough to have a substantial transformation. The product is then sent to MX for packaging and shipped back to the US. This product now consists of the first product shipped […]
QUESTION: I like to know if any member has screened a current US customer of theirs to find they have a DOJ Office of Public Affairs release stating that the customer has resolved a FCPA investigation and has paid a monetary amount to settle for bribes outside the US. I know this is a red […]
QUESTION: We have filed a protest on previously liquidated entries regarding a requested HTS change. CBP CEE has advised they will wait for the CIT court case on a related item to be decided before they decide on the protest. We have current entries (which have not liquidated) falling into the same question of classification. […]
QUESTION: If you are a registered US Defense contractor and you discover that an employee’s green card has expired (for any reason) does this person still qualify as a US person per DDTC/BIS rules? Should we apply for a license to cover the time period between the lapsed date and the expected renewal date? (And […]
QUESTION: Would like the memberships guidance on Made in the USA qualifiers. We would like to change ours to “Made in the US (USA) with Global Materials, – or “Globally Sourced Materials” We manufacture goods that are “substantially transformed” in the US, from US and global parts – complete Tariff shift to a “new and […]
QUESTION: My company is in a temporary situation where we need to export completed parts for testing. We manufacture detailed metallic parts in the US, and will export them to Canada for a supplier to test them for strength, design, etc. The supplier then returns the parts to our facility in the US. The foreign […]
QUESTION: Company A needs to ship a computer stick, which has some additional proprietary software installed, to Company B in China to facilitate the uploading of software to an IMD Company B is producing. The ECCN for the computer stick itself is 5A992C (verified by CCATS). Company A Engineer states additional proprietary software only has […]
QUESTION: As a private company, are we obligated to solicit information from our suppliers on conflict minerals? We supply public companies and therefore receive solicitation requests from them. I am just wondering if we need to use the full Electronic Industry Citizenship Coalition (EICC) solicitation template or a shortened version. Any guidance would be appreciated. […]
