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 […]
Question: In reference to Binding Ruling HQ H155142, the company (manufacturer) in the ruling asked if their Liquid Nitrogen Dry Shipper would qualify as Instruments of International Traffic. CBP said yes. My company owns about 5 Liquid Nitrogen Dry Shippers from the manufacturer. These Liquid Nitrogen Dry Shippers are used for the conveyance of biological […]
Question: When we import something invoiced in Euros, our broker uses an exchange rate on the 7501 to get the entered value in USD. If, let’s say, we want to re-export that item in the same condition as when imported, what should we use as the export value? Should we use the same exact USD […]
Question: Does anyone have an anti-corruption right to audit program or areas that should be address that they would be willing to share? ************* Answers: Large international mfg firm – We upgraded our anti-corruption program by engaging a consultant and installing case management software. All third parties now have to submit an input form that […]
Question: We are a wire producer, who manufactures wire for many applications. Most of our products are used commercially, but some may find their way into military applications. Everything we make is made to order, meeting specific specs for tensile strength, alloy composition, and of course size. These technically aren’t modified and they are not […]
Question: Can anyone share their experiences with exporting hard drives to China. The hard drives do not require an export license and the value is approx. $200? Can we send them via express courier without any problems to our offices in China? ========== Answer: I’m fairly sure the hard drives would require a 3C certification […]
Question: How is your Organization structured to handle Product Classification (e.g. Centralized, Decentralized)? What is the scope of the classification team’s responsibilities? (e.g. HTS, ECCN, CSOO) How many parts are classified per month & how long does the classification of a single part typically take? ============ Answers: Large multi-division company – previously had no knowledge […]
