Miscellaneous

MISCELLANEOUS

  • ORIGIN DETERMINATION AND AUDITING

    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 […]

  • CN PRODUCTS IN BONDED FACILITY

    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 […]

  • BROKER PERMIT FEE

    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 […]

  • TRADE SANCTION SUMMARY

    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 […]

  • TRADE COMPLIANCE FOR A 3PL

    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 […]

  • CF3311 USAGE

    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 […]

  • SHIPPING TO IRAN

    Question: I need to send a good overview of what can be exported to Iran now and what the prospects are for exporting to Iran in the future from a US company.   Does anyone have something they can provide or a link to a easy to understand explanation.  I could not find a simple explanation […]

  • CONTAINER VALUE

    Question: We export a drug filled in the compressed gas cylinder. The cylinder is not registered as an IIT, but it’s re-usable.  At the time of export, the US exporter owns the container. The foreign customer only pays us for the gas inside the container and will return after its use.   1.  Do we […]

  • CONTAINER WEIGHT VERIFICATION JUL 2016

    Question: SOLAS container weight verification that is due to be implemented July 1, 2016. In reviewing the information that I have found so far, it is not clear on the following points: Is the target date realistic? Will the IMO provide a specific document for this new rule? o   If not, how will the details […]

  • CBP UNREASONABLE REQUESTS

    Question: When dealing with an unreasonable requests from CBP (for import or export), what methods exist within CBP to report unjustified behavior from a particular officer?  Does it have to be managed from particular port office?  Does anyone have positive experiences with using these channels?  We clearly do not want to sour the relationship for […]

  • C-LEVEL COMMITMENT

    Question: We just went through a thorough Customs audit and have identified the areas where improvement and change is needed. The current person in charge of imports does not have the knowledge to accurately do the job. Compliance has suggested several times that we hire someone competent in import compliance, but time and time again […]

  • FREIGHT NON-DUTIABLE CHARGES

    Question: Had an argument with colleagues about deduction of international freight when the colleagues were under the opinion that if an international  freight charge is indicated on the invoice in addition to the product value, it does not need to be included in the Transaction Value even though no document supporting this charge is available. […]