Miscellaneous

MISCELLANEOUS

  • TEAR AWAY ORIGIN LABELS

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    Question:   I found several CBP rulings indicating it is acceptable to use tear away/tear off labels on reversible garments.  Can anyone provide any citations that indicate tear away labels are not allowed for country of origin marking for garments that are not reversible? ————————————– ANSWERS: This is under FTC jurisdiction.  Refer to their website: https://www.ftc.gov/tips-advice/business-center/guidance/threading-your-way-through-labeling-requirements-under-textile#place […]

  • LIQUIDATED DAMAGES CLAIM

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    Question: We are a broker and received a notice of liquidated damages for a violation of 19 CFR 113.62 (misdelivery of cargo).   The NVO had full custody of the cargo from door to door.  We only served as the broker and notified the NVO several times that the cargo was up for CBP exam, […]

  • CSD 85-33 AND 85-49

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    Question: Can anyone provide copies of C.S.D. 85-33 and C.S.D. 85-49?   Where are these older documents kept?  Are they available on-line? ========= Answers: Title: T.D. 85-49 February 8, 1985 Foreign Currencies — Variances From Quarterly Rate UNITED STATES CUSTOMS SERVICE                                TREASURY DECISIONS                   19 Cust. B. & Dec. 125                                    T.D. 85-49                                 February 8, 1985    Foreign […]

  • PMS STATEMENT DATES FOR 2016

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    Question: I am not lazy and did some digging around on the CBP website and made a few calls, but cannot find any official list of the PMS Statement dates by month for 2016. Can anybody provide them? *********** Add’l Answer: We have received the past two lists in the Monthly ACE Trade Update.  

  • IMPORTING HOUSEHOLD EFFECTS

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    Question: I am moving to another country for a work assignment. When importing my household goods and personal effects which HTS Code should apply? I am being told that the customs agency is assigning a 35% tariff rate to my goods. I thought HHE and personal effects were to be imported duty free. Does anyone […]

  • HTS & ECCN TO CUSTOMERS

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    Question: We are a manufacturing company that has both  domestic and international customers. Some domestic customers are asking us to provide  the HTS and ECCN for our entire product line. We have given these on a case- by- case basis, with an appropriate disclosure that the information provided is based on our knowledge, but it […]

  • INDIRECT INVOICE PAYMENTS

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    Question: We have discovered that a few of our customers with credit are not paying us directly – but rather having others pay their invoices on their behalf.  For example, one customer in Turkey uses one of several exchange houses in Europe.  Another customer from the Mid East has his US freight forwarder pay us […]

  • NAFTA EXPORT TO THIRD COUNTRY

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    Question:   Can a product that qualifies for NAFTA (Made in US): be shipped to Holland, enter commerce of Holland and sit on inventory shelf for one year, not opened/not advanced in value, be returned to US, enter commerce of US  and then shipped to MX and qualify for NAFTA? ————————————— ANSWERS: No, it has […]

  • OVERTURNING A CCATS

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    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 […]

  • TRADE PREFERENCE QUALIFICATION TIMES

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    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 […]

  • IMPORTING PARTS FOR FIELD REPLACEMENT

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    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 […]

  • DEFINITION OF SHIPPER

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    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 […]