Miscellaneous

MISCELLANEOUS

  • 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 […]

  • GLOBAL BOM ACCESS – EXPORT

    Question: It is my understand that according to the US Regulations, a US Export can include technology such as an email, software or a blue print sent electronically, etc. My question is what if you had a  program or software that international inter-company employees were able to access, in which the international employees had the […]

  • CBP 7512 FILING THRU ACE

    Question: Is anyone doing electronic 7512’s for export through ACE?  If so, can you do it directly in ACE as an exporter or do you need some type of ABI Compatible Software for the interface. *********** Answers: All electronic 7512s must be filed in ACE, and yes, you need ABI software in order to do […]

  • OVERAGE – SHORTAGE PROCESS

    Question: I am trying to make a strong business case and policy to get our operations team and vendor to understand and address overages and shortages .  Our receiving team rarely provides a completed receiving report and the vendor (related party in China) will not comply with providing corrected invoice and pack slip. The vendor […]

  • CANADIAN EMPLOYEES AND CUBA

    Question: How do U.S. companies with a Canadian foreign subsidiary deal with the Cuba embargo and citizens of embargoed countries that work for a Canadian subsidiary? It is against Canadian law for Canadian companies to participate in the U.S. embargo against Cuba. (foreign subsidiary is incorporated in Canada) It is against Canadian law to ask […]

  • HTS FOR CHINA IMPORTS

    Question: I am looking for some best practices from those in similar situations. We are a US based company exporting to our wholly owned subsidiary office in Shanghai. We have about 30 products in our product line in which the Chinese HTS code differs dramatically from the US code. These differences are at the chapter […]

  • TURKISH TAX LIABILITY

    Question: We recently made a shipment of product to a Turkish Firm located in Istanbul. The product was held in Turkish Customs and we were then notified by the Customer that Turkish Customs was requesting an additional Tax Liability to be paid by the Turkish Customer. The Turkish Customer indicated that this “New” Liability is […]