Miscellaneous

MISCELLANEOUS

  • Pharma appendix additions

      Question: Can the membership outline the process and provide contacts for getting an API, intermediate, and drug product on the Pharmaceutical Appendix to the USHTS.   Is acceptance based on the fact the material(s) are already commercial or can products at the IND, or NDA stage be added? ***********

  • Catalog model with options

      Question:   A new product line is developed to target commercial markets and you offer standard options from the catalog where the customer can choose the catalog model but with Options A, B, and C.  If you have a defense application that chooses the catalog model and chooses Options A,B,&C, is the final product […]

  • 1-29 visa requirements

      QUESTION:   Our company does not produce any technology or commodity that is controlled, however, we purchase a commodity that is listed on the CCL of EAR (a Schedule 3 chemical).  The commodity is used in making products for civil construction and is shipped, contained in products, in concentrations below licensing requirements.  My question, […]

  • Permit to Transfer

      Question:   We have volumes of ocean containers arriving to the west coast on a regular basis.  Upon arrival we make entry for merchandise that will remain in the US, and file CF7512 (T&E’s) for cargo that will be transiting the US.  When the proper releases have been received from customs a designated CFS […]

  • High risk suppliers

      Question:     My question is – once you’ve run a supply chain security risk analysis for each of your suppliers, what course of action would you take with suppliers that come back as a higher risk?   Would you drop them immediately from your Approved Vendors List?   Would you demand improvement in […]

  • Duty liability for non-IOR (additional answers)

      Question: Company A places orders to foreign provider (FP) for items at FP’s facility.  FP acts as foreign importer of record (FIOR).  Goods are delivered into warehouse B into Company A’s account as Company A inventory.   Product is purchased landed at warehouse B after unloading. Can CBP go after Company for any unpaid duties, […]

  • Duty liability for non-IOR

      Question: Company A places orders to foreign provider (FP) for items at FP’s facility.  FP acts as foreign importer of record (FIOR).  Goods are delivered into warehouse B into Company A’s account as Company A inventory.  Product is purchased landed at warehouse B after unloading. Can CBP go after Company for any unpaid duties, […]

  • Invoice swap with courier

      Question: Typical Sales transaction from US to EU: USA group company A sells to UK group company B, then UK Company B sells to Customer C in Germany. When drop shipping from A to C, we ask a freight forwarder to switch commercial invoice upon arriving at destination for destination import clearance.  Company B […]

  • Consolidating multiple FTA forms

      Question:   I’d like to get the membership feedback on the idea of consolidating multiple free trade agreement forms into one. We export parts to S. Korea, Mexico, Canada, Chile and Australia that are manufactured by many different suppliers. Is it OK to combine the certificate of origin forms from multiple FTA’s into one […]

  • Intercompany shipping

      Question:   Does anyone have insight or  experience on how to govern non production shipments (i.e. Equipment moving from office to office-outside of normal sales/manufacturing flows). How does your company control or monitor these types of moves.  For example when employee 1 ships internationally to colleague 2 without realizing there is a border?  How […]

  • Inventory recognition

      QUESTION:   We use INCOTERMS 2010 with most of our international transactions and we have a question about inventory recognition with one of our agreements.   On occasion we use “FCA Seller’s Facility (INCOTERMS 2010).  Title to all goods purchased hereunder shall pass to the Buyer upon Buyer’s acceptance of the goods.”   With […]