Miscellaneous

MISCELLANEOUS

  • IMPORTER VALIDATIONS BY BROKER

    QUESTION: In regards to this proposed ruling 84 FR 40302, where Customs Brokers must verify their clients, is this an official requirement?  Our new broker is asking for our CEO’s government ID and want to make sure this is already a requirement before requesting this from our CEO.  I’d like to include the CFR citation […]

  • TRIENNIAL REPORT FILING

    QUESTION: I found out just a couple of weeks ago that my Broker’s License was issued as of January 2021. To give an idea, all I have so far is my license number and a courtesy notice from the port I applied at that the license was approved. Would I still need to file a […]

  • Volume Discounts and Penalties

    QUESTION: My company is looking to enter an agreement with a foreign vendor where we would pay a discounted value post purchasing a minimum agreed volume of product, but if we do not purchase the minimum agreed volume of product, we will pay penalty.  My thinking is that we would use invoice transaction value as […]

  • Custom Brokerage Exam Prep (April 2019 Exam Answer Explanation)

    QUESTION: I am preparing for the 2021 April Customs Brokerage Exam and am currently taking previous exam as practice.  Question #47, from the April 2019 Exam, in the Practical Exercise section has me lost.  A commercial invoice is given to answer 5 questions, with no other instruction or information.  Follow the link April 2019 Exam […]

  • Certificate of Origin

    QUESTION: Scenario: My organization is a chemical manufacture and recently imported US product (USMCA Inventory) to a leased facility as a related transaction. From this facility the inventory is then sold as a domestic transaction within Canada. We cannot guarantee our product is not combined with non-originating inventory at facility. The Canadian customer is now […]

  • PRODUCT STANDARD DETERMINATIONS (UL, CE, NOM, etc.)

    QUESTION: Can anyone share with me where the role of ensuring a product meets UL, CE, MX NOM or any other country specific OGA requirement for safety or standards (Cert of Conformity) lies in your company? I realize these things impact the ability of a company to import into a country but to me these […]

  • VENDOR CHANGE AND SKU ID

    QUESTION: From a C-TPAT and/or General Customs Compliance standpoint, would there be any compliance issue if…  – one of our vendors changed from X (who used Manufacturer C) to Y, – the new vendor Y kept the same Manufacturer C and the Importer of Record kept the same Stock Keeping Unit (SKU) Number for Manufacturer C?  […]

  • WHEN TO TRANSACTIONALLY SCREEN FOR RPL

    QUESTION: In talking with our project management team the discussion for best practices for screening new potential customers in the US came up. I believe best practice is screening before you even contact the company.  My PM asked where an infraction could occur if the quote was presented to the customer due to insufficient screening, […]

  • Citations

    QUESTION: Asking the membership for their assistance in specific citations that enumerate what is required .vs. what is nice to have. Commercial Invoice Packing List SED ========== Answers: For imports see  19 CFR § 141.86 ========== For Items that are controlled. New rules Effective Nov. 15, 2016 as part of the President’s Export Control Reform (ECR) […]

  • Importing Company-Owned U.S. Goods Returning

    QUESTION: I’m fairly new to my position (as our company’s EO) and I’m not convinced the company’s process of re-importing our company’s ITAR/CCL/USML items is correct. I’m therefore attempting to ensure our regulatory ducks are in a row. We file for our own export licenses, file via ACE prior to shipping export-controlled parts/equipment, and we […]

  • Arrival charges

    QUESTION: Who is ultimately responsible for the arrival (ocean) port charges when the Incoterms denote the vendor is responsible for the freight to an inland destination, such as DAP Laredo TX?   My understanding is that any original destination ocean port charges should be paid by the Vendor where the agreed upon Incoterms are DAP […]

  • Hand Sanitizer Destruction

    QUESTION: FDA has hand sanitizers in California that have been refused entry. We need to destroy them, but are being advised that we cannot in California. Does anyone know what states allow will allow destruction of hand sanitizers? %%%%%%%%%% ANSWER: Is the FDA requiring destruction only or can you export them instead?  If you are […]