Miscellaneous

MISCELLANEOUS

  • GENERAL WISDOM IMPORTING AND EXPORTING

    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 […]

  • Offshore Wellhead

    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 […]

  • Unmanifested cargo received in error

    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 […]

  • US CONTENT IN SOFTWARE

    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 […]

  • FUMIGATION CERT DURATION

    QUESTION: Would anyone know the duration for a Fumigation Certificate?  Our overseas vendor had the items fumigated in July, but then was unable to ship due to back-log at origin.  They are wondering how long the certificate would be valid.  Anyone know, or know with whom I should speak?   ========== Answers: A fumigation certificate, also […]

  • Using Microsoft Forms

    QUESTION: Does anyone use Microsoft Forms for vendor solicitation (especially FTA, REACH, RoHS, Prop 65, Conflict Minerals)? What are some positives and negatives to taking this approach? %%%%%%%%%% ANSWERS: The trick is the record keeping and data maintenance by part number.  There are reasonable products that can help you for these projects.  Try looking at […]

  • Foreign Ownership

    QUESTION: Looking for guidance to provide company leadership on the impact of existing DDTC registration IF ownership were to change and equal greater than 50% by a Foreign entity? %%%%%%%%%% ANSWER There is not enough information here to provide solid guidance, but in general everything depends on what the potential organization will look like (structure, […]

  • CONTAINER SHORTAGES

    QUESTION: I am wondering if anyone within the industry has any recommendations on how best to mitigate the challenge of not having containers available for pickup appointments.  We have tried to call the trucking companies assigned the day prior to a scheduled pickup appointment to verify they are able to adhere to their appointment as […]

  • WITHHOLD RELEASE ON SILICA-BASED PRODUCTS

    QUESTION: With CBP issuing a guidance on 6/23 to withhold release orders at all US ports containing silica-based products made by Hoshine Silicon Ind. located in Xinjiang Uygar region, I’m concerned if CBP might do a broad sweep and hold all silica-based products from China. My questions are: Should we request our Chinese suppliers above […]

  • Cryptocurrency

    QUESTION: Does anyone in the membership have information on if there are any export controls around cryptocurrency cross border payments/transfers? *********** Answers: I am not aware of any export controls related to the use of payments based on cryptocurrency for cross border payments/transfers, however, there are some legitimate issues regarding the use of “unofficial” tender/ […]

  • EIN for multiple plants

    QUESTION: I need some guidance on how to set up suffixes for each importing plant instead of all filing under the corporate EIN.  We need to distinguish what import should be assigned to each plant. How is this setup initially?  Through the tax department, finance, etc?  How does it affect the corporate structure, or is […]

  • EEI filings and multiple shipments

    QUESTION: Can anyone point me in the direction of AES or DoC guidance on how to file an EEI for shipments of equipment that is considered to be a system and will be shipped to MX on several different trucks over a few weeks time?   %%%%%%%%%% ANSWERS: This is basically driven by the HTS classification […]