Miscellaneous

MISCELLANEOUS

  • MX TO EU SHIPPING UNDER FTA

    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 […]

  • END USER CERTIFICATES

    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 […]

  • SHIPPING FROM PUERTO RICO

    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 […]

  • END USER SCREENING PROCESS

    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 […]

  • STA AGREEMENT TEMPLATE

    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 […]

  • COUNTRY CRYPTO REQUIREMENTS

    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 […]

  • US GOODS RETURNED WAIVER LETTER

    Question: Has anyone filed a waiver letter with the port director to waive the need for MA and Foreign shipper declaration for imports on US Goods returned? Do you have a format or what information was given to the port to ask for the waiver? Any advice is welcome. ************* ANSWER: Hi did the member […]

  • INDIA VALUE CERTIFICATION

    Question: We have a request from a customer in India, to generate a “certificate stating that prices mentioned in the Invoice are fair“.  Has anyone else received documentation requests like this for exports from the US to India?  How do you handle these unusual documentation requests, especially when this is not a letter of credit […]

  • IMPORT ROYALTIES

    Question: We are going to import a product with a licensed print on it.  We have a license agreement with a third party in the US.  The royalty will be paid per piece that we buy.  My understanding of 19 CFR 152.103(f) is that we would pay duty on the royalty in this case.  Am […]

  • DROP SHIPPING TW TO MALAYSIA

    Question: An agency for our company which sells on our behalf internationally has made a request. Can we have our vendor ship directly from Taiwan to the customer in Malaysia? Aside from the obvious that we could lose all future sales are there legal and / or compliance concerns or situations we should be addressing. […]

  • OPEN HOUSE VISITOR SCREENING

    Question: We are a C-TPAT company and we manufacture controlled products. Our policy is to screen all visitors who enter our facility. My company is planning to invite families and friends to an open house this Spring. If we secure all controlled products and do not allow access to this area during the open house […]

  • Actual vs Principal Use

    Question: Can someone clarify classification and when to consider actual use and/or principal use. I am not comprehending this concept and wondering if some examples of a commodity could be provided or some presentation that will help me remember. *********** Add’l Answer: It’s unclear if you mean ECCN or HTS classification. For HTS, the rule […]