QUESTION: TMP(b)(3) references “foreign origin” items. An aircraft operator in Turkey send me a 9A610 item to analyze and send back (unchanged). Can I use TMP even if the item was manufactured in the USA? I presume in the context of TMP, that “foreign origin” does not mean what we typically think of in the […]
QUESTION: It just came to my attention that we have a US entity who is supported by their related Belarus entity for IT services. The US company pays for the services on a cost plus transfer price. Are these services allowable under the newer sanctions in response to the Ukraine war? ========== Answer: The U.S. […]
QUESTION: Our company currently has different processes for customs invoices, based on shipping location: mix of company owned warehouse and third party warehouse. We are trying to standardize our Customs Invoice process to one process, but there is concern over providing a customs invoice with pricing to third party warehouses. How are other companies managing […]
QUESTION: How long does your company retain visitor logs physically (paper copies)? How long does your company retain visitor logs electronically (scans of paper logs)? ========== Answers: As a rule, 5 years for both types of records. This means that, at the end of 2021, we kept 2016-2021. We typically purge at the end of […]
QUESTION: We have some imports that are set up as pay in advance rather than Net terms. These invoices from our suppliers frequently have an additional banking fee included on it to cover their charge for the wire transfer. If the bank fee is charged directly by the supplier, then does it become a part of the […]
QUESTION: Can freight charges listed on a commercial invoice be distributed through out all of the line items or should it be added/deducted as the full amount on the 7501? *************** If you have a way to substantiate (prove) the freight charges, you don’t need to include that value in the total value of your […]
QUESTION: If parent company A owns 100% of B and 100% of C, are B and C “related” to each other in the CBP 152.102 definition? There is zero “ownership” between B and C. I am looking at the 7 items in 152.102(g). Since there is no ownership relationship between B and C to each […]
QUESTION: What is the proper DDTC helpdesk email? Their website lists ddtccustomerservice @state.gov, but when you send something there an auto reply comes saying it is no longer valid, and to use the “new” email which is the SAME – ddtccustomerservice@state.gov. ========== Answers: This email does work: DDTCResponseTeam@state.gov =========== You don’t say what the nature […]
QUESTION: Scenario: Company A is owner and exporter of goods from a foreign country being shipped to the US. Goods are shipped DDP. We act as IOR into the US on their behalf, house their inventory, and ship components out to their field techs in the US for repair purposes, upon their direction. Company A retains ownership […]
QUESTION: I see that the CBP website has a page announcing the 2022 Trade Symposium in July in Anaheim, CA. Other than this, there’s no link to provide more information. Does anyone have more information about the Trade Symposium or when they will open it up for signing up? ========== Answer:
QUESTION: A bit less than one year ago, we imported a laser, with ECCN 6A005.b.6.b.2, for use in our manufacturing equipment. The laser has since been found to be defective and we will be re-exporting it to the original supplier, whose location requires a license according to the country chart. It has not been advanced […]
QUESTION: ITAR 124.10 states that a DSP-83 is required for *ANY* any TAA involving SME. The newly revised agreement guidelines P 15 says: “If the agreement involves the transfer of classified technical data or *technical data for the manufacture of SME abroad*, state whether a Non-transfer and Use Certificate (Form DSP-83), is/is not attached in […]
