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. […]
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 […]
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 […]
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 […]
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 […]
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 […]
Question: Does anyone have any experience transshipping from Mexico US EU, while maintain the EU MX FTA benefits? Were you able to procure a form CBP or another party that would satisfy the non-manipulation requirements required to claim the FTA? Thanks! ************ Answers: More detail needed as you did not explain what you mean by […]
Question: My company sells/exports EAR99 items as a general rule, no licenses, no high risk countries,and we run the DPL checks daily.From time to time our suppliers will submit a request for us to complete an end use/end user certificate.When I review their commodities, they are clearly EAR99 (plastic parts, metal parts (automotive)), no electronics […]
Question: If we send shipments out of Puerto Rico to other Insular Possessions or Islands, it’s my understanding that these shipments are under the same U.S. export regulations as if they were shipped from the states, is this right? If we ship from the United States to an Insular Possession, it’s my understanding that these […]
Question: I was wondering if anyone has attempted to create an enhanced end user screening process to comply with the BIS regulation against the unlicensed export of many mass market products to military end users/end use in Venezuela and Russia? (15 C.F.R. §744.21) I was curious how this restriction affected others, if at all. Do […]
Question: Does anyone have an example of an agreement that pertains to 740.20(d)(4) License Exception STA “Requirements for releases of software source code or technology within a single country” that they could share? ========== Answer: I believe you can find a basic template on the BIS website which you could then change the wording a […]
Question: Does anyone have a current list of countries that control the import of encryption software with their specific restrictions and requirements? ========== A web-based country-by-country guide to encryption regulations. The following is an illustrative list: Germany, Poland, and the Czech Republic: Notification Required; France: License/Notification required; Singapore and Hong Kong: License Required; China: Certification […]
