Question: Can there be different related party statuses for the same shipment, depending on what documentation is involved? For the EEI and Shipper’s Letter of Instruction, Related Parties refers to the relationship between the USPPI, and the ultimate consignee. But what about for Customs purposes? US plant manufactures product, and sells to Canadian subsidiary, who […]
Question: At http://export.gov/ecr/eg_main_023148.asp, it states that parties listed on OFAC SDN with certain designators (SDGT, SDT etc.) are subject to EAR licensing. I had “assumed†all on the OFAC list would be subject to OFAC licensing.    1)   Does it say this in the EAR anywhere? 2)     Are all the other […]
Question: How long does it typically take to obtain a CCATS ruling response? ************* ANSWERS: Our experience is 3-4 weeks. ************* 30 – 45 days ************* It depends on how much information you provide on the front end. I would say 2-4 based on a recent request but allow for 30 days to be safe. […]
Question: Company A was a partial owner of Company B. Company B was a small volume importer that never had its own import bond and instead either cleared shipments via a courier’s bond. Company A later takes full ownership of Company B, even though Company B still maintains its own unique EIN. While purchase orders […]
Question: Using 9801 when importing U.S. Goods Returned is optional.  If you want to pay duty, CBP won’t complain. But can anyone confirm whether the use of 9801.10.0000 is optional when reporting the export value of repairs in AES? Can we use the “normal” HTS/Sched B if we want? Section 30.29 in the FTR uses […]
Question: We have been approached by a large customer who wants to package our products into their suite of hardware products that make up an entire system. Prior to allowing us to sell our products to them, they have asked for us to verify/validate that our products have been vetted via homologation. *********** See this […]
Question: We have suppliers that declare a defective allowance – i.e. 2 ½% on the commercial invoice. For purposes of valuing the products on the invoice for duty purposes is it proper to pro-rate the value of the allowance across all items declared on the invoice? ************ ANSWERS: Defective Allowances are quite common and are […]
Question: We are a California; USA manufacturer with an additional wholly owned and operated maquiladora (factory) in Tijuana, Mexico. We have a customer located in Guatemala, for this customer we are producing finished goods in Mexico and under the maquiladora rules shipping the finished goods from Mexico to California; USA. We loaded an […]
Question: My company has recently opened a new DC in Miami. We intend to ship things from there to customers abroad. Our company headquarters are in Kansas and currently that is the address that we have on our commercial invoices. My question is, if it is shipped out of Miami, should the address on our […]
Question: All the regulations I could find on Liquidation of customs entries, both the current regs and the Tariff Act of 1930, state deemed liquidated 1 year from entry. I have always been told 314 days and it even says 314 Day Liquidation Period on CSMS 97-000531. I was always taught in school that our […]
Question: I was told by CBP in a Focused Assessment about 10 years ago that misclassifications at the 9th or 10th digit are considered “insignificant” by CBP and that there would be no negative consequences to an importer for such occasional misclassifications. Can anyone substantiate this? ************ ANSWERS: Under your Reasonable Care responsibilities, you should […]
Question: Is anyone planning to submit comments to the proposed rule in the Fed Register that will require the 5106 form to name company officers who have importing and financial business knowledge of the company and will require reporting the Social Security Number and Passport Numbers of those officers? Does your company have objections to providing […]
