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. […]
QUESTION: Our company ships primarily to a US and Canada customer base. We do have some exports but only a very small percentage. All items are EAR99 and are of non-US origin. Most shipments are repeated shipments and to the same customer base. What would be the minimum denied party screening process? […]
QUESTION: Does anyone with the membership have experience with dealing with Tollers? If so is there a check list of the due diligence items required for Tollers. Is there anything specific from trade compliance stand point? ========== Answer: I am assuming that you are referring to a supplier that processes raw materials or semi-finished goods […]
QUESTION: I am curious to hear about the level of due diligence that companies take to resolve potentially “positive” screening results. For example, how do you verify that the John Doe who just placed an order with your company is not the same John Doe who is on OFAC’s SDN List? What steps […]
QUESTION: Under 19 U.S.C. § 1307 it is illegal to import into the United States goods made, in whole or in part, by forced labor, including convict labor, forced child labor, and indentured labor. Is there a list of countries that have known forced labor and therefor sourcing from such a country is a risky […]
QUESTION: Does anyone have a vendor evaluation form/matrix that they are willing to share? We are currently evaluating software vendors for a global trade management solution. ************** Answers: I used the attached (hyper-link)score-sheet last year for our RFP for GTM software. This was used to evaluate the two finalists. http://www.icpainc.org/wp-content/uploads/2014/10/ICPA-GTM-Bidder-Finalists-Scoresheet.xlsx
QUESTION: What is a better way of reporting non-revenue changes / revenue changes that fall under $20.00? PSC or quarterly reports? What is the process of Quarterly Reporting? Is done via ABI? ========== Answer: You should record them for your records, but if they are under $20 there is no obligation to report. ========== Addl […]
