QUESTION: An importer buys directly from a Manufacturer (XYZ) AND indirectly through a 3rd party Vendor who has partial ownership in the same MFG (ABC) from the same Manufacturer: should there be 2 separate MID-codes??… – For the Direct Buy: one Mid-Code based on the Manufacturer name as (XYZ) AND – For the Indirect Buy: […]
QUESTION: I ran across an anomaly in the tariff recently relative to heading 8303. The HTSUS differs from the Harmonized System Convention. • HTSUS: Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the like, AND PARTS THEREOF, of base metal. • HS: 83.03 Armoured or […]
QUESTION: I’m tired of filling out so many different formats of SLI. Does anyone have a sample general one, maybe in Excel, that I could customize for my company? ************** Answers: Attached .pdf and .doc formats. https://www.icpainc.org/wp-content/uploads/2021/03/ICPA-shipper_export_dec.pdf https://www.icpainc.org/wp-content/uploads/2021/03/ICPA-SED-form.doc **************** The NCBFAA has an industry standard SLI posted at its website. Either search on “NCBFAA SLI” […]
QUESTION: Can anyone in the membership share a sample contract clause addressing title transfer at a (named) longitude and latitude location in the ocean? ***************** Answers: I think you need much more than just a contractual agreement, you need to address issues around the ocean negotiable B/L for example as this is considered the title to […]
QUESTION: Looking for advice from the membership about how to obtain work experience in the import/export industry and best method(s) to approach a potential career move. I’ve spent the last 5+ yrs. attaining the broker license, attending workshops & courses to learn/hone classification skills, NCBFAA CES, etc. Yet, when perusing job openings and calculating my […]
QUESTION: Taking into account CSMS 14-000077, we understand that goods entered under Civil Aircraft Agreement that are marked or eligible to be marked the “product of” a country (let’s say Mexico in this case) with which the U.S. has an FTA that provides MPF exemption (let’s say USMCA in this case), can be imported free […]
QUESTION: Our affiliate in Canada sold an item to another company in Canada. They need to buy this item from us in the USA. Their client in Canada cannot take the product, for it is too large and needs to be shipped to a location in the USA , their sister company. This is an […]
QUESTION: I plan on shipping an item enumerated in the CCL to a Military End-User (Coast Guard- not in China, Russia, or Venezuela). Based on the reasons for control for the ECCN and the country of ultimate destination, a license would not be required. However, because of the update to the definitions of Military End-User/Users, […]
QUESTION: For members that are part of the CTPAT program (importer). When you send out a supply chain security questionnaire to your supplier base and the supplier answers “no” to some questions, how do you handle these types of responses? For example, do you: Accept the answer as is Respond and ask for explanations. Once […]
QUESTION: We’re a small company and I am the only person dedicated to our export control program. To comply with the annual audit requirement, what best practices are there for small companies to perform EC/ITAR program audits? Is it acceptable for me to perform the audit, or should it be a third party? %%%%%%%%%% ANSWERS: […]
QUESTION: How do other companies maintain that their 3rd party companies screen and vet their customers, suppliers and vendors properly? In other words how far do you go with a 3rd party agent? Do you feel it’s necessary to screen and vet an international bank that will receive wire transfers as well ? ========== Answer: […]
QUESTION: We just acquired a company that’s been using the wrong tariff code (duty free, no China tariff) for a product they were importing. We have started to use the correct code (duty free + 25% China tariff but there was an exclusion until 12/2020). What is the recommendation for previous entries using incorrect code […]
