Miscellaneous

MISCELLANEOUS

  • EXPORTING SAND MOLDS FOR TESTING

    Question: I am not familiar with casting/molding so the terms are throwing me off, but we want to export sand insert cores as well as some samples to a potential supplier for testing. The inserts are compressed silica sand coated with phenol-formaldehyde. Aside from my doubts that they will arrive in one piece, I don’t […]

  • CASH POOLING

    Question: Has anyone had experience using Cash Pooling when importing from a related party? Are there procedures you have added to your compliance manual to keep this as a low risk process? My biggest concerns are the         1.    lack of clear tracking from invoice to payment     2.    any ongoing overage/shortage between what […]

  • CONCENTRATED JUICE DUTY CALCULATION

    Question:   We are considering importing lemon juice concentrate products under HTS 2009.39.6020.  We understand that the duty rate of 7.9 cents per liter is based on a liter of natural unconcentrated fruit juice or to a liter of reconstituted fruit juice.   Brix values on this product will range from 42.00 to 55.00.  Is there […]

  • HTS SIMPLIFICATION PROCESS

    Question: What is the process to formally ask the US government to simplify some harmonized codes? This would only be for changes at the country-specific, 10-digit level and would not affect duty. ==========   Contact the Office of Tariff Affairs and Trade Agreements at the U.S. International Trade Commission, James Holbein, Director, point of contact […]

  • SNAP-R LICENSE APP

    Question: Can someone please advise the following regarding SNAP-R license application? 1. Documents submitted with application.   Do we still need to Import/End-User Certificate? I have heard there is a new rule stating that this certificate is not required anymore for some items and countries.  When do we have to use Import/End-User Certificate and BIS-711? […]

  • TPP

    Question: The USTR recently published a Summary of the US Objectives for the Trans-Pacific Partnership (TPP) negotiations. Is there any other information that may be out there that could provide more details, especially with regard to textiles and apparel? The report says that the rules of origin will focus on a yarn-forward approach. I would […]

  • REGISTERING WITH STATE DEPT

    Question:   I am a manufacturer of items designed for commercial use, and 99% of the time this is how they are sold/used.   About 1% of the time an ITAR/DDTC registered customer asks for my items.  I tell them that I am not DDTC registered, and that the items are not ITAR (they truly […]

  • SALES OF IP-BASED PRODUCTS

    Question: I work for a U.S. based international company that is regulated by the FDA and we are currently researching the development and sales of IP based products. This is a new arena for us and I would like to ask the advice of the membership regarding where Trade Compliance should focus their efforts in […]

  • MERGER CHECKLIST

    Question: Our company is in the process of merging two operating units.  We are currently working on updating bonds, changing FTZ, C-TPAT, etc.  Since is the first time we have experienced a merger we want to make sure we do not miss anything.  Does anyone have a checklist or guideline they have followed that might […]

  • C-LEVEL EXEC COMMUNICATION

    Question:   For all of you “wordsmith’s” out there –   Looking for the best way to respond to C level executives from different divisions on how best to advise them that the HTS classifications they have been using are not “correct”, and that by relying on their soon to be former customs broker company, […]

  • MID AND ISF

    Question: We have the following scenario and would appreciate opinions from other members: PO is issued to Vendor (Seller) A for apparel goods manufactured by Factory F. ·         Factory F subcontracts sewing of garments to Factory S.  ·         Both F and S have a relationship to Vendor A, but S is not related to F […]

  • ACCOUNTING FOR R&D

    We are looking for a more efficient way to account for R&D in our annual reconciliation formula. Do members have any examples that they can share where they developed a method to account for foreign R&D that is not “project based” R&D, such as a using a % of foreign R&D to include in their […]