Question: Having a debate within our company as to where management and responsibility of SOLAS should reside. I believe this is more of a Logistics process and should fall under Global Logistics and of course Logistics believes Trade compliance should own and manage. Who is right – or who is MORE right given it […]
Question: We will begin a process w/an express courier handling low value shipments for the company. When exactly is a power of attorney required: 1) Section releases – we believe not 2) Informal entries – since express couriers make themselves the IOR we believe a POA is not required for this lane but […]
Question: It’s uncommon that our company has controlled technology, but we have a situation where one of our projects has technology controlled under 1E001. We need to store this data in a system in a cloud based in Europe to be in line with company R&D requirements; it would be far from trivial to […]
Question: We have a binding ruling that was issued by CBP several years ago. Based on later rulings issued to other importers, we believe our classification is now in error. In order to have CBP review the same product again, should a request for modification be sent to the NY NIS or directly to […]
Question: My company’s import manual has not been updated for a few years. As part of the update, I am updating my distribution list. Should the distribution remain within my company, or should I send a copy to CBP (port account manager, the CEE for my commodity, our local port, regulatory audit, etc.)? We are […]
Question: Would appreciate getting the memberships comments regarding the proper country of origin marking for goods produced in Bethlehem, Palestine VIA Israel. We’re having internal discussion whether the goods should be marked as “Made in West Bank” vs. “Made in Israel”. We’re currently leaning toward using the “Made in West Bank” on the basis […]
Question: We are trying to figure out where the conflict minerals investigation and reporting responsibility would be better served. Can members please advise where this reporting requirement falls within your company? Some typical options include: Legal Sourcing/Procurement Trade Compliance Ethics & Compliance Regulatory Compliance Engineering Other ================ ANSWERS: It’s under Regulatory & Compliance in […]
Question: We are involved in clinical study where out kits consists of drugs and placebos. The kits are given to a doctor where either the drug or placebo is given to a patient and results are recorded for the study. When these kits, of the above, are imported into Germany, there is a ruling (see […]
Question: We recently sent equipment to Malaysia for demonstration purposes under a Carnet. We would like to do a partial return, however, we were told by our US agent’s destination office that partial returns are not “encouraged” in Malaysia and they recommended that we bring the entire shipment back. I confirmed with our surety that […]
Question: Prior to entries being filed through ACE, we would file qualifying de minimis corrections via quarterly reports directly with various ports. How is the membership community now treating de minimis corrections? Are you having your broker create PSC corrections for all corrections to entries including de minimus situations? If you are choosing to […]
Question: I would like to ask the membership if anyone does vendor payments in their local currency, and if yes, please highlight process and paperwork requirements, more from a customs perspective. I have been tasked with looking at this opportunity as a means of saving additional dollars due to currency fluctuations. Our systems only handle […]
Question: I’m looking for suggestions on how to curb unauthorized clearances by some forwarder/brokers. Despite written instructions advising that all shipments are to be turned over to broker X, clearances are processed (on the offending parties bond) and a bill for duty/brokerage submitted to us for payment. Regardless of the quality of the documents provided, […]
