QUESTION: Can the membership please weigh in on how the new de minimis rules apply on EAR99 items produced outside of the US in US owned foreign plants, for products destined to Russia, no military end use or military end user? ============ Answer: I do not believe de minimis rules apply since there is no […]
QUESTION: We are receiving request from our customer to register with CargoX as ACI is now a requirement for all import/exports. Can someone confirm? It appears, as the exporter, we would upload the docs into CargoX ? How are other company handling this? ========== Answers: Yes, we’ve been doing this for about 6 months now. […]
QUESTION: I am hoping the team can provide me with advice on how to move forward with remaining in the EO (Empowered Official) role reporting to Sales and Development? This is a major conflict of interest and everything I have shown our leadership has fallen on deaf ears. The training and seminars I have requested […]
QUESTION: My company is a humanitarian group that ships pharmaceuticals and medical supplies throughout the world. A lot of our partners are small clinics who don’t always seem to have the ability to clear their country’s customs in a timely manner. We end up getting delays at customs, fees start adding up, etc. We currently […]
QUESTION: I would like to send a bottle of bourbon to a friend in Brighton England. Of course it’s a gift and I would want to ship it DDP. Please advise, I do not have a clue so tell me everything I need to do. ========== Answers: You answer is also dependent upon where the […]
QUESTION: I am trying to compile a list of questions to provide to senior leadership to (1) address prior to making an offer for an M&A and (2) a list of questions to pose post offer/acceptance to help ensure the company’s trade team is well advised of all potential risks for the M&A and able […]
QUESTION: How are members handling the Uyghur Forced labor research? Are you contacting all of your vendors to get a letter from them that they are not using forced labor from Uyghur? (or any for that matter). Are you sending out a letter to your vendors and storing in a database? Do you have a […]
QUESTION: Are there still sanctions for exporting to Venezuela? Can any company ship to Venezuela or do all items need export licenses? =========== Answers: Ah, yes. You have to make an export license determination for every export to Venezuela or anywhere. Most significantly, the government of Venezuela is blocked. Since many companies in VE […]
QUESTION: What should a company do if it hasn’t submitted its’ self-classification report pursuant to 740.17(b) and it’s late? I would appreciate any kind of input in this area. I am a new hire at an importer/exporter of Chapter 85 products. It’s a pretty good company which is interested in doing things correctly. Since I’ve […]
QUESTION: I would like to ask the membership if they are experiencing issues using HTS# 3002.15.0091. which changed over from 3002.15.0090 This is a new 2022 HTS# and it appears in the USITC’s website, yet our Customs brokers is indicating that the 3002.15.0091 HTS is invalid. Stuck in the middle. =========== Answers: Until CBP updates […]
QUESTION: For companies that have products requiring SDS/MSDS sheets, which department is responsible for creating them (e.g. EHS, Regulatory Affairs, etc.) and does that include drafting equivalent versions for other regions in the world, like EU/UK REACH? Has anyone ever seen this housed within a Trade Compliance department? ========== Answers: So MSDS are no longer […]
Question: We have a foreign subsidiary that is looking to re-export a US item that is subject to the EAR and is classified as 5A002. If the shipment was leaving from the United States, it would be authorized under the ENC license exception and reported through the AES system. It is clear from the EAR […]
