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 […]
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 […]
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 […]
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, […]
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 […]
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 […]
Question: I am wondering if there is any way to bring garments back in the US duty free if they are being returned for cleaning. The company that I work for has retail stores in Canada. All garments are originally imported into the US from Asia, and are then shipped to the company’s retail […]
Question: I am responsible for import/export compliance training at a few different offsite locations across the US. It is not always feasible to travel to those destination to provide in-person training. I have been scheduling WebEx’s but not getting the attendance I had hoped. Some people are just too busy as they are answering the […]
Question: What is the difference between a Free Trade Zone and a Free Industrial Zone and what are the cons of being in one of these zones? We are considering placing a new chemical manufacturing facility in either China, Taiwan, or Malaysia. ************* Answers: Both a Free Trade Zone and a Free Industrial Zone […]
Question: Does anyone have a list of all CAS #’s on the USML? We are trying to put an excel file of only these CAS #’s together. ************* Answers: Those would be found under USML Categories V and XIV. However, . . . you can’t consider those as exhaustive, because – for example – […]
Question: My company has decided to begin dealing in ITAR technology. As the head of trade compliance, my plan calls for me to be designated as the Empowered Official. My management has questioned if ITAR responsibility belongs with trade compliance. Any members who deal with ITAR: can you please comment on what department and […]
Question: Our publically traded company is splitting into 2 separately traded companies. I know this is not an uncommon practice but I am seeking lessons learned. 1 company will have to establish literally everything: IOR€™s Bonds Customs Broker Agreements Agreements / contracts with service providers ie: freight forwarders, small package carriers. Potentially a new contract […]
