Miscellaneous

MISCELLANEOUS

  • SPLITTING BOL AFTER SAILING

    Question: Here’s a new one, on me at least; we have a shipment to China where the customer cannot pay for the full amount of the goods (shipping in 3 containers).  So they want us to re-consign 1 ½ containers to another, related party (related to them).  Has anyone ever done this before?  Is it […]

  • DUTIABILITY OF CUSTOMS FEES

    Question: Upon return of items that have been repaired/re-worked in Germany, our supplier has added a line on the commercial invoice for “Import Customs Fees”.  I have been told that they are charging our company back for import fees/duties that are applied when the items ships to Germany.  They separate the line on the commercial […]

  • CHEMICAL SAMPLE IMPORTING

    Question: As an importer of chemical samples, we want to be 100% compliant with all requirements under DOT/IMDG/IATA/OSHA, etc. and the new GHS label initiative. To effectively do that, our product compliance team conducts an extensive review which includes an evaluation of supplier labels, often resulting in several days of email dialogue.  Due to this […]

  • ON-SITE BROKER REVIEW

    Question: Can the membership provide guidance of what an on-site visit to a customs broker facility for purposes of auditing the customs broker consist of?  What would the agenda look like? ************** ANSWERS: I would start with A meet & greet of all associates assigned to work on your account Broker to provide a clear […]

  • GLOBALIZING HTS CODES

    Question: I’m just wondering if any of the members have encountered foreign governments insisting that their products are classified using different tariff numbers than the U.S., making the HTS anything but harmonized?  For example, we manufacture Integrated Circuits which have always been classified as 8542.  We have a new product that we applied for a […]

  • APPAREL TERMINOLOGY

    Question: The terms artificial, synthetic and man-made all appear very close and can’t find a good set of definitions in the tariff, explanatory notes or informed compliance publications. Does anyone have a key of what fabrics fall under which provisions ? ************** Answers: When I was taking the broker exam, I did not classify apparel […]

  • ANTI-BOYCOTT COMPLIANCE

    Question: I am struggling with an Anti-Boycotting issue and could use some help. Section 760.3 (a) permits U.S. companies to “comply or agree to comply” with the Arab League Boycott , due to the importing requirements of that country. If this means a U.S. company may refuse to provide goods or services of Israeli origin […]

  • COLOMBIAN HTS CODE FORMAT

    Question: I need to load Colombian tariff codes into our system, and want to utilize the proper formatting. Should they be (for example) 2710193500 or 2710.19.3500 ************ ANSWER: Based on the Colombian legislation the formatting should be XXXX.XX.XX.XX

  • CORRECT USPPI

    Question: If our company, the USPPI, employs a 3PL to ship and file EEI for our exports, should that 3PL be listed in AES Direct as the Freight Forwarder?  (The 3PL in these cases is not performing a freight forwarder function.  The 3PL is not booking cargo space). If the 3PL should be listed as […]

  • TRADE COMPLIANCE STRATEGY

    Question: We are looking to better understand how other companies are managing this same challenge in pharmaceuticals/Biotech, or another “like” industry.  Most recently the conversation about Trade Compliance has turned to organizational structure and operating model.    Here is a list of the type of information that we are looking for:   ·         Global presence […]

  • CBP5106 FILING

    Question: We are getting ready to submit Form 5106. Looking for confirmation from the group: Box 7  = Mailing address for any CBP Notices or Correspondence only. Box12 = Corporate Legal address that needs to match the address of the Surety Bond. Anyone ever have any issues with filing the 5106 for a mailing address […]

  • OFAC EXPOSURE

    Question: Here’s a scenario: Company ABC designs/develops an EAR99 product in the U.S. ABC’s factory in China uses the U.S. technology to make the product, and deliveries are made directly from China to customers in various countries. One of ABC’s customers is a South Korean company (an OEM with no U.S. ties whatsoever). This customer […]