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 […]
QUESTION: In a routed export transaction, if the inland freight cost is not included in the reporting to commerce, who is ultimately responsible for this error? ========== Answers: Who hits the send button to transmit the EEI? EEI compliance is ultimately the responsibility of whomever files the EEI, whether it’s the FPPI in a typical […]
QUESTION: I work in the US office and warehouse of a private, foreign -owned company based in the EU. We have recently been bought out and are now owned entirely by a private US firm. My question is; since our ownership is now entirely US, as is our corporate governance does this make our warehouse […]
QUESTION: Do I have to add inland freight charges & insurance costs to my EEI value if I am not paying for the inland freight or any insurance? ========== Answers: Ah, yes. Who’s paying for it is not a factor in the value to be reported. Keep in mind on this particular topic that estimates […]
QUESTION: We purchase product from a supplier in the U.S who imports the product from overseas. We then use that product in the manufacture of our finished goods which does qualify as substantial transformation. Our customer has requested the Country of Origin on the raw materials (copper and wire) which I have no issue providing. […]
