Miscellaneous

MISCELLANEOUS

  • TUNING RESTRICTED PARTY SCREENING

    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.  […]

  • USML VS CCL FOR KC-46

    QUESTION: The KC-46 is in 9A610, Military Aircraft and Related Commodities, Other Than Those Enumerated in 9A991.a., correct?9A610.y speaks to specific parts, components, accessories and attachments specially designed for a commodity subject to control in this entry, ECCN 9A619, or for a defense article in USML categories VIII or XIX and not elsewhere specified in […]

  • Verification of the authorized use of Customhouse brokers

    QUESTION: Has anyone ever received an inquiry like this from a CBP Regulatory Audit & Agency Advisory Services Office of Trade? Started with a phone call from an Assistant Field Director asking about if we use ABC broker and a specific Entry number was provided.  Assistant Director said they were investigating the ABC Broker. I […]

  • SEC 889(a)1)(A) COMPLIANCE

    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: We do not sign this type of certification unless we have documentation on file from our supplier to validate they […]

  • IMPORTING W/O MILL CERTIFICATE

    QUESTION: We are a manufacturing company importing a carbon steel item that requires a steel mill certificate and is also eligible for Anti-Dumping Duty (ADD) upon import to the USA.  Our supplier has told us only the country of origin but refuses to impart to us the required manufacturer’s name and address.  What is the […]

  • RECON LINE REJECTED DUE TO PROTEST

    QUESTION: For those that participate in Customs reconciliation program, have you had any issues recently with a line or lines on the entry being rejected because a protest was done? How were you able to resolve it? **************** Answers: See page 22 of the new “ACE Reconciliation External Handbook,” published August, 2020 for guidance: 2. […]

  • Customs business question – liquidation extension

    QUESTION: Can I request a liquidation extension on behalf of our related party or is that considered Custom Business? %%%%%%%%%% ANSWER: I believe you can if your position includes providing corporate oversite for that related party. Otherwise if you do not work for the related party, I would agree it is Customs business and you […]

  • Trade compliance council development

    QUESTION: Reaching out to ICPA membership to share ideas to create a trade compliance council.  I’d like to create a corporate task force with the mission to assist trade compliance staff, which is very limited, to bring representation from other business groups to identify risks and help with creating process and procedures. Also, to share […]

  • US GOODS RETURNED ENTRY CONSOLIDATION

    QUESTION: Our USGR process is manual today and the commercial invoice is generated during the time we process a “return label” online via our carrier.  If we itemize the CI, the commodity lines we are importing back to the US will exceeds 100+ lines.  As long as all items falls under the commodity HTS code […]

  • SIGNING SHIPPING INVOICES

    QUESTION: When shipping through a third party warehouse who typically signs the commercial invoices? In our situation the warehouse is only printing the invoice, so it doesn’t feel right to ask them to sign it. We are not sure if someone in trade compliance should sign off on it, or someone on the order entry […]

  • Additions to PAPP – Proceeds of subsequent reales, disposal or use

    QUESTION: I’d be interested to learn from the import community about their understanding of “proceeds of subsequent resale, use or disposal.  Does the resale or use have to be a direct, 1 to 1 resale or can there be mixing or dilution of the imported product involved in the resale.  By that I mean, you […]

  • Naval aircraft goods

    QUESTION: If you are selling goods to the U.S. Navy and the goods are to be used on a naval aircraft carrier, are the goods considered to be on US soil or would they be an export while they are on the ship?  The question arose during a discussion and I am curious if the […]