Miscellaneous

MISCELLANEOUS

  • CUSTOMS RULINGS 544194 542519

    Question: Can any of the members provide a copy of rulings 544194 and 542519? They are not available in CROSS. Thanks! *********** Answers: Doc No: HQ 544194 Title: Title not found Fuglei Added ruling, exclusively from CUSTOMS Info HQ 544194 MAY 23, 1988 CATEGORY: Valuation FILE: CLA-2 CO:R:CV:V 544194 EK HQ 544194 TO : All […]

  • 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 […]

  • CBP INSPECTION LIABILITY

    Question: Exporter shipped his household goods in a 40’ container to the UK.  The shipment consisted of household goods, an auto, and lots of tools in padlocked toolboxes. Customs inspected the container prior to export (due to the vehicle).  The container arrived at the CES with the shipper’s seal intact. There were several large padlocked […]

  • SUPPLIER PUSHBACKS

    Question: I would like to ask the membership on how they overcome challenges in explaining US regulatory requirements to suppliers – e.g. Blocking & Bracing, UN Marking on Drums, content and format of labels, etc.  Often time suppliers believe that these requirements are purely  “our” requirements or “our”  interpretation of the rules and often tell […]

  • POST-ENTRY AUDIT PROCESS

    Question: We are currently auditing our post entry at 100%. We have an actual process in place but I am looking to make it more efficient and present to my manager for approval. Can someone share with me their post entry process? ************ ANSWERS: Our Compliance Department has a goal to audit 100% of the […]

  • RECON TIME EXTENSION

    Question: Is it possible to get a company’s reconciliation due date extended by CBP? I know that value reconciliation is due 21 months after the entry summary date, can we get this extended? Otherwise what are the options if a company is not able to file timely? ************* ANSWERS: Yes and no.  The actual time […]

  • VISITOR RPL SCREENING PROCESS

    Question: We’re trying to implement a new visitor RPL screening process and management has some questions about the necessity/ how other companies handle this.    I would GREATLY appreciate any feedback re: the fact that RPL screening for visitors/tours is an expected component of an export compliance program & how it is handled at your companies. […]

  • ANTI-BOYCOTT REPORTING

    Question: Can anyone from the membership advise what the potential  violation and associated penalties are for not reporting an anti-boycott statement in a timely manner. **************** ANSWERS: If you’re asking whether you can include a reportable item that should have been submitted in a previous reporting period in a current report, I believe the answer […]

  • SPLIT IMPORT SHIPMENT

    Question: Company A is the importer/customer Company B is the foreign exporter/Vendor Company C is a second customer of Company B Company A is asked to import a container of product. 75% for Company A, 25% is to go to Company C.  What is the proper way this container is to be imported if Company […]

  • HQ RULING HQ114411 NOV 1999

    Question: Looking to see if anyone has access to a copy of Headquarters’ Ruling HQ114411 from November 22, 1999. ========== Answer: Doc No: HQ 114411 Title: Employee Leasing Company; Customs Brokers; Customs Business; PROP TO REV HQ 113867 & MOD HQ 226101    Gen. Notice Link                            ATTACHMENT D                            HQ 114411                                  BRO-1-RR:IT:EC 114411 GG CATEGORY: Brokers Ronald […]

  • IMPORT OF CITRONELLA CANDLES

    Question: Are any of the membership registered with EPA to import citronella candles? Is it a requirement? ========== Answers: yes it’s a requirement ========== Citronella candles require an EPA entry(and a TSCA form), because citronella is considered a pesticide http://www.epa.gov/oppt/import-export/pubs/sec13.html Register with the EPA, and file an EPA entry for each Customs entry- it is […]

  • CORPORATE COMPLIANCE ACTIVITY

    Question: Pursuant to 19 CFR 111.1 “Customs Business” is defined as not including a Corporate Compliance Activity. Would the following scenario equate to a Customs Broker undertaking a Corporate Compliance Activity ? Foreign supplier (China for example) provides documents (commercial invoice, packing list, etc) to the Customs Brokers foreign office, to make an ocean freight […]