Miscellaneous

MISCELLANEOUS

  • TRIANGULAR SHIPMENT

    Question: We sell to a company in the Netherlands and ship to one of it’s divisions in Mexico. The Commercial invoice that accompanies the shipment currently shows sold to Netherlands Company, ship to Mexico Company, seller Our Company US. Is this correct? Or should the buying company provide its own invoice for this transaction? Additionally, […]

  • CONSOLIDATED ENTRY SUMMARY

    Question: Are any of the members consolidating their entry summaries as allowed under 19 CFR 142.17 (combining individual entries on to one consolidated summary?)  If yes, does the MPF cap on the summary at $485? ************** Answers: Yes, the cap on a consolidated entry is $485.  This will change however when the new MPF restructuring […]

  • RIGHT TO MAKE ENTRY

    Question: Our scenario: We consign the HBL to our customer ABC company where the container will be delivered as a drop ship.    Our company XYZ is responsible for the clearance and final delivery. The commercial invoice shows our company XYZ as the buyer and ABC as the ship to party (financial interest). Question, does the […]

  • USPPI SCENARIO

    Question: In this scenario who would be the USPPI for these FCL shipments? My overseas customer has asked to include other US purchased goods from other suppliers and/or from a large retailer in their future FCL shipments.   Surely the large domestic retailers would not be willing to provide written authorization for the EEI filing, as […]

  • FTA RESOURCES

    Question:   We are a large CPG manufacturer with a very limited trade compliance staff relative to the size and scope of the business. Due to recent cuts, we are facing the loss of one of four people, and the targeted position is solely responsible for soliciting, reviewing, and cataloging the underlying vendor certifications that […]

  • INHOUSE BROKERAGE

    Question: The Customs regulations allow for an individual to handle brokerage business in the capacity of representing his or her interests.  Can an employee of a company, especially one that conducts business using several different entities, handle brokerage for that company without an actual broker’s license? *************** Answers: Yes I have done it for 8 […]

  • SOLAS OWNERSHIP

    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 […]

  • WHEN A POA IS REQUIRED

    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 […]

  • CONTROLLED CLOUD STORAGE LICENSES

    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 […]

  • BINDING RULING REVIEW

    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 […]

  • SHARING IMPORT MANUAL WITH CBP

    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 […]

  • WEST BANK MARKING PROCESS

    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 […]