Miscellaneous

MISCELLANEOUS

  • NHTSA HS7 Form

    Question:   Very specific line of questioning. We’ll be importing  pieces of automotive equipment that are non-compliant under FMVSS (and non-DOT) and are provided to motorcycle teams to be used solely for competitive motorcycle hard/closed- track racing purposes (not motocross).  This would lend to choosing option #7.  I’m finding out that AFTER racing, our sales […]

  • CORRECTIONS POST LIQUIDATION

    Question:   My previous broker left me with a small mess- I have a few transactions where we had asked the broker to file PEA’s, and the broker kept putting me off until after liquidation, so now too late for a PEA. Of the items needing correction, two are classification changes with no duty consequence, […]

  • CORRECT SHIPPER ON BOL

    Question:   On a Waybill, you typically have a Consignor, Consignee and a Shipper.   Suppose the scenario is as follows:  We are the Consignor selling FCA, point of origin, to Company X in Japan. Under FCA, we are clearing for export and they are handling transportation.  Who is the shipper?  I have had people tell […]

  • CIRCUMSTANCES OF SALE

    Question:   I found out that the interpretation of the third example of the circumstances of the sale test ambiguous not only in the U.S. but worldwide.   The test states:   “If it is shown that the price is adequate to ensure recovery of all costs plus a profit which is equivalent to the […]

  • DEALING WITH COLLEAGES

    Question: Someone from another subsidiary has convinced my boss that his services are invaluable to my company and he would be helping us with some logistics functions that we have been doing. My job is compliance, but I was requested by my boss to step in with supply chain and delivery issues to make sure […]

  • POA

    Question:We’re a Limited Liability COMPANY (not a Corporation). Does issuance of POAs to customs brokers require signature from an OFFICER of the LLC ? Appreciate reference to any specific statutes; am dealing with contentious corp law dept colleague. If officer signature IS required, is delegation to non-officer as simple as validating a Schedule A-Authority schedule […]

  • CARGO STOWED AT SHIPS CONVENIENCE

    Question: When break-bulk cargo is tendered to a break-bulk vessel, if the vessel operator decides to load the cargo into a container for “ship’s convenience”, how will the importer have this information 24 hours prior to lading? Importers will most likely not have this information until after sailing. The Advance Cargo declaration requirements link cited […]

  • SHIP CHANDLERS

    Question: #1 – If any of the members are shipping product to US based ship chandlers, who then sell products to either foreign or domestic flagged vessels, what is your process for determining whether the shipment is an export or a domestic shipment? If the ship chandler is buying for stocking purposes, do you treat […]

  • MID FOR DIFFERENT SUPPLIERS

    Question: We are an apparel importer. We have come across a unique situation. We have 3 factories that all have similar names from the same area. Based on customs formula, they all result in the same MID code. Has this happened to anyone? How do you handle the different manufacturers with customs? CBP won’t allow […]

  • DEPT OF LABOR AND STATISTICS

    Question: We had a call from the Bureau of Labor and Statistics – wanting information on our prices we pay on our imported merchandise. Has anyone else every received this call? Why would the Bureau of Labor and Statistics need this information?

  • ILLEGAL TRANS SHIPMENTS

    Question: Our company feels like we take very good reasonable care measures to monitor possible illegal transshipment. For example, we proactively request production records and perform risk based analysis to identify high risk shipments. I am wondering what other companies do to prevent or identify illegal transshipment

  • LACEY ACT PHASE IN

    Question: To date, I’ve only seen APHIS/CBP notices for the Lacey Act implementation which specify the phase in schedule solely at the Chapter level. Has anyone else seen something issued by the government which actually lists the phase-in schedule by tariff heading and phase-in date???