QUESTION: Does anyone have any experience with the process to update a statistical note to the HTS? =========== Answer: It depends on what you want to do, but you would start with a submission or request to the appropriate Tariff Affairs Branch of the U.S. International Trade Commission (https://www.usitc.gov/offices/tata) explaining why a modification of the […]
QUESTION: I am wondering whether we need to look into DDTC registration. Here’s our potential scenario: We are not developing a product to sell into the defense industry, our product is strictly COTS (Commercially- available off the shelf). Our partner we may work with is asking us to sign an attestation form and access a […]
QUESTION: We use a 3rd party supplier in the US to ship internal orders to our international locations. On the Pro Forma, they indicate a US HTS Number, yet shouldn’t it be the Schedule B? Also, we are often contacted by the broker to further provide EU HS codes for our EU locations. Could we […]
QUESTION: Where would the most likely classification be for plastic components that are sold to a company that will use these components to assemble into a drone killing drone UAV product. These plastic parts are used for the exterior assembly of the drone, but the parts do not have any technology to aid the drone […]
QUESTION: The drawing from my customer states that the parts and components I am selling to them are controlled by the CCL. Is that sufficient to classify in the CCL given the fact that my customer is a renowned manufacturer of ITAR products and has classified the items on the drawings they provided? My parts […]
QUESTION: Customers are sending notice our company is to be compliant with Section 889(a)(1)(A) and will be asked to certify such compliance. Question: Should our company be surveying our Suppliers for the same compliance? %%%%%%%%%% ANSWERS: This is usually associated with Defense Contractors and is a requirements of defense contractor acquisition agreements. So, if you […]
QUESTION: When we SELL internationally inter-company, we use a CBP approved transfer price markup for transaction value (and approved by CBP equivalent in destination/import country). But when we export WARRANTY items inter-company, we use COST (no markup / no transfer price). Is cost acceptable to use for customs valuation between related parties in this […]
QUESTION: If an item is specifically named in a 600 series ECCN in a .y category, and the item is used on both military and civilian articles, and not elsewhere named in the CCL, can this item ever be EAR99 when the .y states specially designed? When, if at all, are you allowed to classify […]
QUESTION: I get an enormous amount of false positives when doing Restricted party List Screening. My match threshold is at 95%…there is nowhere else to go but 100%, which makes me nervous. My question is this: If I load 30,000 parties to my screening tool, I may get around a 2-4% fail rate…600-1200 potential matches. […]
QUESTION: When a broker does not know the freight / insurance charges on an inbound shipment, I understand an estimate is made in box 32 relative to those charges. If I don’t know the actual and I do not deduct those charges, am I ultimately held accountable for those estimates as entered by the broker […]
QUESTION: I’ve seen varying answers on this website concerning how to determine the country of export on a CBP 7501. I would like to see a clear response on how to make this determination. If I have a supplier in France that sells material to me and the place of receipt of the goods showing […]
QUESTION: On the EEI, Box 4a, is the Ultimate Consignee the Notify Party that appears on the OBL & 4b the Intermediate Consignee the Sold to Party that appears on the commercial invoice? In a recent audit it was pointed out that we have not been completing 4b. It was noted that although this was […]
