Miscellaneous

MISCELLANEOUS

  • Bourbon to Britain?

    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 […]

  • Prior and Post M&A Questions /During TSA Period

    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 […]

  • Uyghur Forced Labor

    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 […]

  • VENEZUELA SANCTIONS & LICENSES

    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 […]

  • LATE SUBMISSION OF SELF-CLASSIFICATION REPORTS

    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 […]

  • HTS 3002.15.0091 FAILING

    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 […]

  • MSDS / SDS SHEET PREPARATION

    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 […]

  • License Exception Reporting for Foreign Subsidiary Re-Export

    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 […]

  • Routed Shipments

    Question: Per INCOTERM FCA….EEI filing is to be the seller BUT what if the US seller is only delivering to customers forwarder US location OR the customers forwarder is picking up at our US location?  The export is all being handled by the FPPI and the FPPI’s forwarder. How would the USPPI file the EEI […]

  • HTS VS SCH. B SCENARIO

    QUESTION: With the recent HTS modification HTS 3402.20.5100 was update to 3402.50.5100.  The new HTS of 3402.50.5100 is not in the schedule B, but is still listed as 3402.20.5100.  The importing country does not have the old HTS of 3402.20.5100, because of the HTS update as well. What should the export documents reflect regarding the […]

  • KN95 masks with various expiration dates

    QUESTION: We are a humanitarian group that provides medicines and various medical supplies throughout the world. We received a large donation of KN95 masks and noticed each pallet had a number of different expiration dates. It would take a lot of time and effort to sort through and organize them by expiration date. We’re looking […]

  • Sufficient Evidence of Freight

    QUESTION: Like many importers, we are looking to introduce cost savings for our imports.   One such initiative is reducing our duty by deducting the cost of freight under C- and D- incoterms.  We understand only actual charges can be deducted in accordance with T.D. 00-20, various rulings, and the Customs Valuation Encyclopedia section on Transportation […]