Question: I just started as import backup at a new company that makes rubber seals/gaskets. Most of our products are EAR99. A customer asked me to send a list of all dual-use items. How do you know if your commercial parts are also being used by some customers for military purposes? How do you determine […]
Question: We are headquartered in the US with divisions worldwide. Our biggest manufacturing facilities outside of the US are in China and India. We manufacture some valves that are considered dual-use according to the CCL. If China manufactures these items and they are not subject to the EAR according to all provisions in § 734.3, […]
Question: We will be applying for FTZ activation early next year and I know that both are required for FTZ activation. We have already obtained a bond. From my understanding, we need to obtain a FIRMS code, then apply for FTZ automation. What is the process of obtaining a FIRMS Code? How is it separate […]
Question: In screening a potential customer I ran into pretty good evidence that the individual is posing as an employee of a company that he does NOT work for, which was confirmed by the company represented. He is in the UAE and was attempting to be set up as a customer in order to purchase […]
Question: We are required to use one of the express carriers for all shipments that we pay for when possible. This is a nightmare for import compliance. We now require the carrier to contact us for instruction for EVERY import shipment so that we can provide proper instruction. Most shipments are items coming in from […]
Question: It has recently come to our compliance department’s attention that our dealer/distributor (whom we’ve received the order from and are invoicing) in the Dominican Republic is allowing their customer (End User) to Route the freight from the US. The End User is IOR into DR. My concern arises with a.) the End User is […]
Question: We have reviewed the MERCOSUR Agreement (Southern Common Market) and are looking for specifics on duties charged between the member countries (Argentina, Brazil, Paraguay, Uruguay and most recently Bolivarian Rep. of Venezuela). There is mention in the Agreement of the elimination of duties for the member countries but there is nothing spelled out […]
Question: Would any members have a listing, by country, of value thresholds where formal-type entries are not required and instead can be cleared by a courier service ? ************* ANSWERS: I do not believe a simple one-size-fits-all list exist. When I did some sample research on the three express carrier/courier websites (all of them have […]
QUESTION: The ITAR states in 22CFR Ch.1 Subchapter M 120.3 An article or service may be designated or determined…to be a defense article if it…. (a)…and (i) Does not have predominant civil applications , and … The question is When reviewing a new product in development that is similar but not the […]
QUESTION: have a question regarding the phrase, “exported or destroyed under Customs supervision” that appears throughout 19 CFR. Is this phrase implying that the shipment can only be exported back to the party that shipped the goods or can the shipment be placed into an FTZ? *************** ANSWERS: There is no implications […]
Question: for companies that import full containers, do you have a maximum number of containers that can shipped on a bill of lading? The maximum for our company is 10 per bill of lading. If we have 30 containers shipping from the same supplier at one time, we will have 3 separate bills of ladings. […]
Question: My company is currently debating which functional area should be responsible for ensuring compliance with the FTC requirements, namely the verbiage to be used (Made In, Assembled In, Product Of) before the country to be named. Could you please share which functional area makes such determinations for your company and ensures compliance with the […]
