Question: I have recently discovered a large Chinese supplier of ours has been deflating the customs value on the commercial invoice while billing my company actual cost for the accounting invoice. I am reviewing our entries and am only noticing this practice on express courier shipments in which our small package courier company is handling. […]
Question: I would like if anybody could share procedure for on online sales for distributors that offer products produced by your company around the world and which export clauses are recommended to have with distributor in order to make sure that products do not end on prohibited countries due to diversion since the company will […]
Question: I hope one of our attorney members or other members with experience can offer some clarity regarding license exception RPL. Specifically, §740.10(b)(2)(i) says: €œServicing€ as used in this section means inspection, testing, calibration or repair, including overhaul and reconditioning. The servicing shall not have improved or changed the basic characteristics (e.g., the accuracy, capability, […]
Question: In your organization what department is responsible for D&B registration (DUNS)? Who maintains the registration? When inquiries come in asking for your company’s DUNS number to whom (department or title) are the inquiries directed? ********** Answers: DUNS registration is usually handled by an accounting or credit department. DUNS is a type of credit reporting […]
Question: Where can I find information on Customs’ website regarding section 321 entries? Also does anyone utilize section 321 entries with freight forwarder or ocean shipments, or is the section 321 primarily used for courier shipments only? ************** ANSWERS: Section 10.151 or 321 can be used for goods valued not over $200 and can be […]
Question: Can any wood importers (Ch. 44) share how they know that their imports of wood products weren’t harvested illegally? We currently receive the Lacey Declaration from our vendors, but we have no proof that the products are not illegally harvested. Does anyone go further than merely requiring the Lacey Declaration, to get more proof […]
Question: Does anyone have any start up guidelines for importing children’s apparel / products? Safety, testing, labeling, classifying? ************** First of all, know the Consumer Product Safety Improvement Act (CPSIA). To that end, start here: http://www.cpsc.gov/en/Regulations-Laws–Standards/Statutes/The-Consumer-Product-Safety-Improvement-Act/ Every style must be tested for CPSC compliance by a CPSC-accredited lab, which includes testing for flammability, small parts/choking […]
Question: We are looking for guidance from companies that have had experience with CBP’s Reg Audit folks. Customs has notified us that they would like to “come in and review some of our entries”. At this time we have no knowledge of any particular issue that they might be looking at. In such a case, […]
Question: Does anyone have a good definition of what Customs considers “visible lining”? ========== ADDITIONAL ANSWERS: From an apparel standpoint, visible lining is what it says: the lining (permanently attached) that is visible. This would be as opposed to other linings inside a garment, such as interlinings (usually hidden behind a shell fabric facing if […]
Question: Our company is considering participation in a Center for Excellence and Expertise (CEE), but have some reservations. What are the benefits your company has experienced, and what (if any) are the potential risks/downsides of participation? Has anyone in the community had any negative experiences with a CEE? Your thoughts and comments are greatly appreciated. […]
Question: Does anyone have a good definition of what Customs considers “visible lining”? ========== Answer: I don’t know if this helps, but General Note 12 of the Tariff Schedule (NAFTA), Chapter 61 Rule 2 specifies the following regarding visible lining: If the rule requires that the good must also satisfy the tariff change requirements for […]
Question: I am struggling to write a procedure on how our Company should handle items that are being carried back from China. I have to educate employees and do it fast. 1) This includes: Prototypes, Samples , Parts samples & for production or resale Samples coming back can vary from a fabric sample to an […]
