QUESTION: We don’t import anything on the high risk list of goods produced by forced or child labor. Should we still implement a process for verifying our suppliers’ manufacturing locations outside the US? If so, what are members doing to check all the vendors locations when they don’t import goods produced by forced or child […]
QUESTION: Does the consignee country need to match the destination country on a certificate of origin? The factory cannot issue one C/O for consolidated shipment from CN because the destination is in the UE and the buyer is located in the UK. %%%%%%%%% ANSWERS: Is this a drop shipment? Are you confusing a Certificate of […]
QUESTION: We imported lumber over 10 days ago, but since it was not heat treated at a high enough temperature at origin, CBP issued an Emergency Action Notice saying that we have to send it back. Duties of $40 are scheduled to be paid ~Sep 22 under Periodic Monthly Statement. Where in the regulations does […]
QUESTION: Is a BIS-711 End-User Statement required if my shipment is NLR? When might I want this with an NLR shipment, and when might I not? %%%%%%%%%% ANSWERS: Technically a BIS 711 is not a requirement however the totality of the circumstances needs to be considered. It is dependent on a number of factors – […]
QUESTION: I’m looking for best practices to perform a deeper drive in sanction party screening. In most cases, the party exercising the task at hand only has limited information (name of entity, address, tax ID) so, learning about company officers or subsidiaries require further research. How do you learn about these when all you have […]
QUESTION: Would the membership kindly share supplier due diligence questionnaires with respect to trade sanctions, FCPA, and forced labor? =========== Answer: Is this for large volume vendors only? If so, what value? You may want to approach this similar to an M&A due diligence perspective and then cut back on the line of questioning. You […]
QUESTION: I am a US company and I have an FTZ subzone. The vendor is in Italy. We want them to send goods to the States on consignment. We don’t want to take ownership of the goods until we need them. That vendor doesn’t have a US entity. What are my options? Can my FTZ […]
QUESTION: We have an inbound vessel containing 3 separate HBL’s with corresponding 3 separate MBL’s, all sent from the same foreign vendor, to the same US port, to the same consignee. We want to know if we are supposed to combine all 3 shipments into 1 entry, or if we are supposed to file 3 […]
QUESTION: I’m creating a 101 level presentation to give to employees about the import/export processes. I would like to give some general wisdoms/observations that I’ve learned over my career but are you are not normally taught in classes/seminars so they know what to do or avoid when dealing with imports/exports. Some of the examples I […]
QUESTION: For those of you in the oil-patch, how do you classify a production wellhead? 8481.80.9050? 8481.40.0000? Or somewhere in 8431? ************** Answers: Thank you for stipulating ‘production’ wellhead. Offshore is interpreted as subsea. A complete wellhead, having valves/fittings/tubes/pipes would have a use of controlling flow of liquids. A subsea wellhead’s valves are typically going […]
QUESTION: The importer received in error an unmanifested package as part of a consolidated entry from its affiliate company in Germany. The package should have been part of a different consolidation headed to Singapore. The goods in the package are worth about $4,000. 1) Can the goods be sent directly on to their final destination […]
QUESTION: Software is being developed by a non-U.S. company outside of the U.S. There are U.S. citizens employees, some in the EU, some in the U.S., working on the software. Does this mean there is some U.S. content in the software? Is the work of a U.S. citizen in the U.S. considered U.S. content? Is […]
