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 […]
Question: We would like to obtain some guidance with the following case scenario, regarding the consent to screen air cargo sent by freight forwarders: Company A (US entity) sells its products under EXW Incoterms® their dock. The title of the goods gets transferred to company B, once the merchandise leave Company A premises. The […]
Question: We are importing steel that requires a steel mill certificate per CFR 141.89. The part was made in 1997 and certificate is no longer available. Our broker released the entry flagged for “missing documents” and allowed the container to be delivered to us. We now have 90 days to produce the certificate. […]
Question: I am looking for a consolidated list of the biological agents that are considered dual-use by the US (on the CCL) as well as by the EU, specifically the UK. There is much overlap but I’m not sure that they are identical. Have any members consolidated the two lists and if so, would […]
Question: Does anyone know when we might start receiving the automatic refunds for GSP eligible products (assuming they were entered using the prefix on the HTS)? ========== Answers: The individual ports started liquidation processing on July 31, if you have an ACE account, you should be seeing your GSP refunds in the liquidation reports. ========== […]
Question: We would like to ship goods direct from China to a customer in Wales. The product would be polyester bed linen. Our customer wants the goods to ship DDP, but we do not have an entity in the UK. We are a US company that has a related company in France. Would it be […]
Question: When assigning HTSUS – is the packaging taken into consideration if certain products are imported ready for market? ========== Answer: If the packaging is non-reusable, the packaging assumes the HTS of the contents. Addl Answer: Refer to the General Rules of Interpretation GRI 5 GRI 5 (a) Camera cases, musical instrument cases, gun cases, […]
Question: I work for a company that makes proprietary software (of US ORIGIN), but this proprietary software runs under an open source operating system. In order to satisfy open source software license requirements, we must make available the source code for the operating system. The open source operating system contains many thousands of subroutines, written […]
Question: Our Sales force is required to screen all new leads, contacts, companies,visitors, and contractorsagainst over 100 lists. The software is great, but what I am being told it that for some culturesthe customer will not provide a first or full name. It is initials B.BXXXX or SSS. A.J for example. The software uses fuzzy logic which […]
Question: We have one U.S. goods return from Canada. It’s an used and expensive machine, originally made in U.S. The country of origin is U.S. But we purchased a while ago and can not locate the original paper work. So it’s difficult to ask for NAFTA or manufacturer’s affidavit from the manufacturer. In this situation, […]
Question: Has anyone successfully recently used the CBP 4455 certificate of registration for exports from the USA, in order to re-import them duty free? I haven’t used this tool in many years, wanted to make sure it is still viable ============= Answers: Yes, still useful with CBP at the southern border. ============= Yes, we still […]
