Miscellaneous

MISCELLANEOUS

  • INSIGNIFICANT CLASSIFICATIONS

    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 […]

  • PROPOSED CF5106 GUIDELINES

    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 […]

  • INSTRUMENTS OF INTL TRAFFIC

    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 […]

  • AES RE-EXPORT VALUE

    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 […]

  • ANTI-CORRUPTION PROGRAM

    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 […]

  • WIRE FOR MILITARY APPS

    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 […]

  • HARD DRIVES TO CHINA

    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 […]

  • CLASSIFICATION PROCESS

    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 […]

  • TOOLS OF THE TRADE RE-EXPORT

    Question: This is regarding  a vendor serviceman (from Spain)  came to one of our facilities  to fix their  instrument but he left some tools and parts and asked us to shipped them back (they may be too heavy to carry to the airplane) , he will pay for the shipment. These tools are screw drives, […]

  • POAs

    Question: We are a large US multi-national corporation with a primary corporation with several subsidiaries (each having their own EIN) that import regularly. To minimize the number of Customs powers of attorney that we have to manage, is it possible to issue a primary POA with an attachment detailing the subsidiaries and their corresponding EINs […]

  • TREASURY GUIDANCE BLOCKED PERSONS OWNERSHIP

    Question: I have a question for the  membership. I would like to know how other companies are handling the new guidance issued by Treasury with respect to entities owned 50 percent or more in the aggregate by more than one blocked person. What processes/ tools are others using to help their company comply with this […]

  • OVERAGE SHORTAGE PROCEDURE

    Question: We have a related party foreign supplier who occasionally ships overages.  Internally, the receiving process allows for a PO to be amended for the extra items through a systematic approval process. Is it best to obtain a revised invoice and pack slip from the supplier for the entry amendment? What documents are necessary for […]