Miscellaneous

MISCELLANEOUS

  • COMPLIANCE IN NONUS COUNTRIES

    Question: I’m wondering if anyone has a resource that will help with the regulation requirements for other countries?  For example, our company is a global company headquartered in the U.S.  However we deal with trade in many other countries. I’m looking for a resource that could help realize the level of responsibility our divisions in […]

  • INFRINGEMENT OF PROPERTY RIGHTS

    Question:   We buy foreign made component from a U.S. distributor.  We send this component to our maquiladora operation as a raw material for production into our finished product.     The ITC has recently filed a directive that will disallow this component to be imported into the U.S. because of an infringement on property […]

  • FREIGHT COSTS ON INVOICES

    Question: Our foreign manufacturer is a related company that sells to us at a transfer price. We are using transaction value as the basis for appraisement. Our terms of sale have been FOB port of loading so we never had to manage freight deductions as part of the import declaration.   In an effort to […]

  • REGARDING SELF DISCLOSURE

    Question: My company purchased a company last year, and we have discovered a NAFTA import violation for which we would like to submit a self-disclosure to CBP.  Our question is whether or not we submit the self-disclosure for the importing period of the corporate purchase forward, or if we should go back for the entire […]

  • SEPERATION OF LOGISTICS

    Question:   Can someone help me find written guidelines on keeping compliance and logistic functions separated, and why we do this? Our logistics department continues to insist we use brokers based on current freight contracts, and because they are ‘competitive’ choices.     I know, I know we don’t want to do this,  but I have to […]

  • TRADING WITH GUERNSEY ISLAND

    Question: I am running into contradictory and confusing information in regards to Guernsey Island.  I’m hoping some of you have experience in trade w/ Guernsey and can offer your insight.   According to The Official Guernsey Government Website, “Guernsey (or the Bailiwick of Guernsey) while not being part of the EU is part of the […]

  • BUY AMERICA AND ARRA

    Question:   Under Section 1605 of the ARRA it states that funder cannot be used on a project unless “all iron, steel and manufactured goods used…are produced in the U.S.“  It also states that Section 1605 must be consistent with US obligations under International Agreements (including NAFTA).   An Iron fitting is cast in a […]

  • PAPERLESS INVOICES FOR COURIERS

    Question:   One of the courier services is pushing their paperless invoice system lately and we are nervous about agreeing to it given the broad authority it seems to provide them in their Terms and Conditions of Service – especially as related to export/import services.  The exports we use this courier for are samples of […]

  • INTERMEDIATE CNEE

    Question:   I would like some input on how members are dealing with the Intermediate Consignee field for AES filing. Scenario is an intercompany shipment where a foreign subsidiary is the FPPI for a sale to an end customer (no export licenes) . The end customer is listed as the ultimate consignee.  The foreign sub […]

  • PHARMACEUTICAL IMPORTS FOR HUMAN ANDANIMALS

    Question: Are there any pharmaceutical members importing finished pharma for use for both humans and animals?   If so how are you handling the imports? To clarify there does not seem to be a combined animal/human use for HTS or FDA product code screen is attached as an example.   Are you obtaining USDA Import […]

  • REQUESTING PRODUCTION RECORDS

    Question: Do you periodically request production records from your vendors to support country of origin claims when utilizing free trade programs such as AGOA?  If so, how often do you request production records (quarterly, yearly, etc.)?  Do you have penalties in place with your vendors if they cannot produce the requested documentation?