Miscellaneous

MISCELLANEOUS

  • MIEU Rule and Foreign Subsidiaries § 744.22

    QUESTION: Can anyone please expand or offer specific guidance into how related parties are impacted by § 744.22 (MIEU Rule)? I understand the definition provided in §772 for “U.S. Person” which includes “…Any juridical person organized under the laws of the United States or any jurisdiction within the United States, including foreign branches…” We are […]

  • Proof of Payment for Customs Valuation Inquiry

    QUESTION: Looking for guidance from the trade as to how to provide individual proof of payment of an import invoice when the product was shipped under a Global PO and paid under the Global PO? What details would be provided to Customs so only the information requested is provided? %%%%%%%%%% ANSWERS: Go to your accounting […]

  • WHEN TO OBTAIN SHIPMENT INSURANCE

    QUESTION: We are a small company with about $7,500,000 in export value.  Certainly not a lot compared to other companies  We always get spot insurance when we ship but we are trying to figure out the “tipping point” of when we should get a global policy. If you add in domestic, it’s another $7,500,000 in […]

  • Landed Cost Formula

    QUESTION: Is there a standard landing cost formula? Can anyone offer an example/insights, please? ************** Answers: Landed costs are a cross-functional team effort especially in complex scenarios with multiple variables. There is no one-size-fits-all formula.  Many or most of the cost line items are not within the purview of Trade Compliance.  Further, in many cases […]

  • HOSHINE WRO

    QUESTION: Has anyone found an official list of Hoshine’s subsidiaries and can share? %%%%%%%%%% ANSWER: I ran a D&B report and found several subsidiaries in it.  However, I’m not sure that is the most efficient report that will disclose what you’re looking for. ================================================================

  • RETROACTIVE PRICE ADJUSTMENTS

    QUESTION: We would like feedback from the membership on options / best practices for handling retro-active price adjustments (raw material adjustments for example) for cross border transactions. Company A in the US sells metal stampings to Company B in Mexico. Company A wishes to recover steel price increases from Company B per contractual agreement. %%%%%%%%%% […]

  • STRUCTURE OF POLICIES MANUAL

    O QUESTION: For those of you with a large global operation, how are your policies and procedures structured? Do you have a general corporate trade compliance manual and then specific country procedures? Or, does each country have their own completely separate trade compliance manual? I was thinking, one global TC manual with general principles. Then, each […]

  • ALUMINUM IMPORTS AND AIM PROGRAM

    QUESTION: Does anyone import aluminum products from China that fall under the AIM program with an import licensing requirement. If yes, please advise if the process to apply for a license is simple and an estimated time for completing the application. I have an entity falling under this licensing requirement and they are requesting additional […]

  • Dutch import entry documents

    QUESTION: This is a question for trade compliance members who audit Dutch import entries. I am auditing my first Dutch Customs Entry from the US as we do not have a fully staffed logistics/trade compliance team in the EU/NL.  I am having difficulty tying the invoice PNs to the information on the Customs Release document […]

  • CORPORATE POLICY FOR CUSTOMS REQUESTS

    QUESTION: Does your company have a policy that reads anything like “If a Customs agency asks you for something, please notify Trade Compliance before responding?”  If so, would you mind sharing the verbiage? Is it a separate policy, part of a larger corporate policy, or……? ========== Answers: While I cannot share the exact wording, I can […]

  • Question on job title

    OT Fact Sheet: Origin Certification Requirements QUESTION: I am currently the Trade Compliance Manager. I report to the Director of Supply Chain and then I have a Trade Compliance Analyst that reports to me. We are a US based company with only 1 location and I have been with this company for 13 years. The […]

  • Forced Labor supply chain evaluation approach

    OT Fact Sheet: Origin Certification Requirements QUESTION: I’d be interested to hear from members that have done an evaluation of their end to end supply chain or are considering an evaluation of their end to end supply chain for forced labor – What approach did you take to conduct your evaluation?  Direct survey to suppliers?  […]