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 […]
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 […]
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 […]
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 […]
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 […]
QUESTION: One of my sales guys has a customer in Singapore and would like to be able to provide said customer product on a DDP basis. But we are not in Singapore, we are in the US. We do not manufacture the goods, we are only a sales office. The goods are shipping from our […]
QUESTION: Hoping to poll the community on best practices for obtaining and maintaining Country of Origin for raw materials/components purchased from 3rd parties 1. Any best practices or advice for obtaining COO from suppliers (e.g. pull from invoices during item receipt, manage the process through procurement/time of purchase, etc.). 2. In an ERP, is it […]
QUESTION: I am working to get my company convinced to move forward with ACH payment to CBP but there are questions about Debit vs Credit payments . I am interested in to hear if anyone is using the Credit method and if so what are the pros and cons of that? I have received a […]
QUESTION: We have a device that gets mounted to a product. Our device records activity of the product. The resulting data that our device generates then gets sold to the owner of the product. We have no way of knowing if the product ever enters Iran, North Korea, etc….. but if the product were to […]
QUESTION: With the increased stress levels we are all currently experiencing in our trade we are looking to lighten up the mood a little bit. What would be a fun slogan or motto for an international trade department? ========================================================= Answers: I like the question! “Trade Geeks”? In my company Legal, Tax and Compliance were grouped […]
QUESTION: Need your help! Does anyone have an Extensive International Repair/Return program, that I could benchmark with you on? Please feel free to reach out to me directly : JLeafer@its.jnj.com We are moving our Repair depot to Mexico, however; the contract that was negotiated (without TC) would be for monthly Billing. This will not work […]
