Question: Here’s the background: I got a new job at a software company. Currently reviewing all their ECCNs. They farmed out the self-classification and SNAP-R to a third party on one of their products recently. The third party pitched BIS a 5D002 (b)(2) on that product. BIS ruled accordingly – we got (b)(2). The product […]
Question: We are a CPG manufacturer that is asked to certify a large number of complicated products under various FTAs each year, namely NAFTA and CAFTA. Although we begin gathering the necessary product information from our customers in early October, and we begin soliciting certifications from our own vendors that cover various key components around […]
Question: We sell components to a foreign customer. Recently, a need came up where our US field service engineer flew out to our foreign customer to replace parts on a component under warranty. Compliance pushed back on allowing the parts needed for the repair to be sent to the hotel where the field engineer was […]
Question: I am looking for a regulatory definition of “shipper.” It seems that customs does not define exactly who can act as the shipper. Is there a source someone can cite or direct me to? Is there a legal precedent that a freight forwarder would follow when deciding if one can be named a shipper […]
Question: Our company subscribes to and uses automated screening software. I had a match for the first time today because the company I screened was on a list called the Iowa Public Employees’ Retirement System’s Iran/Sudan Prohibited Companies Lists. Does anyone know if this list is a concern for exporters? Any advice on how should […]
Question: We have a situation where the retail sale price changed on an apparel order after the original set of hang tags had already been attached. Our supplier had to create a full new set of hang tags, remove the first set and then attach the new set of tags. Our questions are: 1. […]
Question: I am in a discussion about country of origin determination and auditing. Different countries have different rules for determining COO at time of import. At what point do you sit back and accept the COO listed on the invoice or certificate of origin? i.e. some countries, like Mexico, will say that a 35% added […]
Question: If domestic Chinese products are moved into an FTZ or bonded facility for further processing, is this considered to be a “virtual export”? If yes, is some kind of customs processing required before the goods can be received at the FTZ? ========== No, it is not an export of any kind when domestic merchandise […]
Question: Is the custom broker permit fee for 2016 now set up to be paid electronically or does the CBP still require a paper check? Is the bulletin out yet? I want to pay my permit fees this month since I will be out of the country in January and want to avoid mailing a […]
Question: Does anyone have a “one-pager” that would describe/define the US trade sanctions/embargoes to your foreign distributor or dealer network? I would like to give them a short one page summary of what the restrictions are. We are dealing in all non-licensable goods (EAR99). ANSWER: Each set of sanctions is different, so there is no […]
Question: As an Exporter (USPPI) and Importer of Record (IOR) we are all aware of our responsibilities and obligations regarding trade compliance along with its many levels. However, what compliance is there for a 3PL operation where the 3PL either has no Freight Forwarding, nor Customs Brokerage activity or associates themselves with an actual Freight […]
Question: I recently received a request form my import broker to complete two Certification Forms on items being returned to our US company for repair that had been initially sold and legally exported to a foreign country. The foreign party placed the “US Manufactured Goods Being Returned for Repair/Replacement” statement on the Commercial invoice and […]
