OT Fact Sheet: Origin Certification Requirements QUESTION: We stock aircraft parts, some of which are on the USML, some are on the CCL, most are EAR99. We sell these to only U.S. companies; what is our due diligence when determining their plans to potentially sell these to foreign end users? ************* Answers: If you are […]
OT Fact Sheet: Origin Certification Requirements QUESTION: My company has a part that has encryption. We already filed with BIS for a CCAT#. We didn’t receive a CCAT# yet. 30 days have already passed. Can we send the part to customers in Russia? =========== Answers: I would not send it. I would follow-up with BIS […]
OT Fact Sheet: Origin Certification Requirements QUESTION: Is it ever legal to have the date pre-printed on a Certificate of Origin when it’s used for preferential treatment? ========= Answers: Yes ========== I would have to say no, unless the date and the date of the signature are the same. The date represents the date on […]
OT Fact Sheet: Origin Certification Requirements QUESTION: If a company imports liquid/bulk shipments, what volume should be declared, the one notated in the BL or the one provided by the inspector that certified the loading quantity and quality? %%%%%%%%%% ANSWERS: Section 151.47 states using gross or net from the Customs accredited commercial lab (inspection co.) […]
OT Fact Sheet: Origin Certification Requirements QUESTION: I have a drop shipment scenario for a EAR controlled item, not ITAR. PO Transaction: – USA Customer (A) purchases from USA supplier (B). Supplier B’s warehouse is located in China. Supplier B places an intercompany PO to China warehouse. – Customer (A) wants Supplier (B) to drop […]
OT Fact Sheet: Origin Certification Requirements QUESTION: In the FR on April 26, 2021, there was a notice that the USTR posted a technical amendment about product imported under 9903.88.09 between May-June 2019 that leave open the possibility of filing for refunds of duties. I checked my entries and most of the entries have already […]
OT Fact Sheet: Origin Certification Requirements QUESTION: Unbeknownst to our logistics and trade compliance team the HR Dept outsourced the ordering and shipment of company gifts given to employees free of charge like tee shirts, hoodies, thermoses, mugs, key chains, hats etc. This is not an issue for domestic shipments. However, I have concerns about […]
OT Fact Sheet: Origin Certification Requirements QUESTION: Curious to know how members label their products that are sold in the US- (products could be of US or foreign origin.) ========== Answers: Goods which are US origin are not required to be labeled with country of manufacture. Goods of foreign origin are required to be marked […]
OT Fact Sheet: Origin Certification Requirements QUESTION: We engage a third party service provider to support our FTA work. We have provided them our e-signatures along with a letter approving their use. We have granted the third party POA as well. We send them all our data, they complete the analysis, create the cert and […]
OT Fact Sheet: Origin Certification Requirements QUESTION: We are getting some push back on the requirement for an End Use Certificate from some of our sales team and distributors. Could someone please share with me what your process/requirements are for an End Use Certificate prior to a sale? Who is required to provide an End […]
OT Fact Sheet: Origin Certification Requirements QUESTION: My company acts as an agent for a company in The Netherlands. We only act as the importer or record and help with coordination of the delivery upon arrival in the US. The delivery terms are DDP and the purchase and subsequent invoicing are between the US customer […]
OT Fact Sheet: Origin Certification Requirements QUESTION: Are you treating subsidiaries of military end users the same as a military end user? The parent of one of our potential suppliers is listed on the BIS Entity list due to allegedly being involved in military activities. Our PO with them would not be with the parent. […]
