Miscellaneous

MISCELLANEOUS

  • FTZ FDA ENTRIES

    Question: I would like to ask the membership for those who have knowledge and or participating in an FTZ in which the imports are applicable to FDA.  From my understanding, under an FTZ, one entry is completed per week.  What happens if and/or when FDA places a hold on a particular item? Does the entry […]

  • TIB IMPORTER / EXPORTER

    Question: Is it possible or does it state in the Regulations, that the importer has to be the exporter on a TIB? ************ ANSWER: No it does not. However, one must be careful to clearly spell out on the export documents that the article is being exported to cancel a TIB, state the TIB number, […]

  • BROKER SELECTION CRITERIA

    Question: Does anyone have a selection criteria for Customs Brokers ? Elements to take into account when selecting a customs broker? ********* ANSWERS: Entry fee rate and entry fee rate.  My benchmark is $85 and $15 respectively, based on 1000 entries per year.  Most CHB brokers have the same capabilities and offer similar services.  The […]

  • MID CODE ERRORS

    Question: While conducting an internal audit of 2014 Ball Bearing entries from MX to US, it was discovered our broker used the wrong Manufacturer ID on many 7501s.  They used the MFG IDs  of other suppliers in Mexico we have that the broker also performs the entries for on our behalf. This issue was first […]

  • RMA PROCESS

    Question: I have been asked to develop an RMA process for the company I work for here in the UKand was wondering if anyone had any guidance they could offer. *********** Answers: I work for a US company.  We import product from China and pay duty.  Some of our product gets sold to customers in […]

  • CORRECTING EEI FILINGS

    Question: During a routine internal export audit, I discovered a shipment with two AES ITNs on a single the HAWB which shipped approximately a month earlier. Additionally, I also discovered a typographical error by the freight forwarder on one of the two AES ITNs listed on the HAWB. The shipments were originally scheduled as separate […]

  • GLOBAL RECORD RETENTION POLICY

    Question: I have been tasked with crafting our International Records Retention Policy.  I’ve been told that the Board wants one policy, not separate ones for each country. This policy is supposed to cover Trade Compliance and also to be relevant to larger Legal needs. Does anyone have any advice or examples?  Anywhere I can go […]

  • MX – ISRAEL PREFERENTIAL TRADE

    Question: Does anyone have experience with exports to Israel? We have a customer in Israel that purchases products from us that have both US origin and MX origin goods (maquiladora). The goods produced in MX are imported into the US to our manufacture facility, consolidated into a container with our US produced goods, and exported […]

  • EU VAT EXCLUSION

    Question: When a qualifying and originating articles are imported into the EU (From Sri Lanka to the Netherlands for example), the duty rate will be 0%, however is VAT also exempted or must the VAT tax still be paid upon importation ? I cannot find any information in the EU Directives, the EU Tariff (TARIC) […]

  • UNIVERSITY / RESEARCH COMPLIANCE

    Question: For members collaborating with universities/ sponsoring research, what kind of export compliance monitoring & reporting do you require from the sponsored entity?   Our std sponsored research agreement calls for mutual obligations to advise ECCN for any Technology provided by either party if the ECCN is other than EAR99.    Recently we encountered a university […]

  • UK/EU VERSION OF CROSS

    Question: Is there an UK or EU version of CROSS available for HTS rulings? ********** Answers: Yes. It is TARIC ******** I used to assign EU HTS and was not aware of anything like this.  I used the EU HTS book on-line and went as close to the US HTS as I could. ************ Yes, […]

  • COMPLIANCE MANUAL SIGN-OFFS

    Question: Our Compliance Department is currently reviewing and revamping our Import Compliance Manual and SOPs. Our SOPs have a three-tiered structure. Level 1 is a high level overview of a process. Level 2 SOP are process flow charts. Level 3 SOP are the step-by-step how-to instructions. Our previous Compliance Manager signed off on all of […]