Miscellaneous

QUESTION: As we know BIS amended the restrictions to Huawei entities listed on the Entity Lists. Current state: There are no license exceptions available for exports, reexport, or transfer (in-country). When a party is on the Entity List is involved, and acts as a purchaser, intermediate or end user. This will prevent Huawei to circumvent […]

QUESTION: Scenario: Company A exports a customer’s used merchandise from the US to Company B in Germany for calibration. They declare the shipment as $200 at the time of export using one of the acceptable methods of valuation. Company B returns the items to Company A after completing the Calibration service. They also issue a […]

Please see the message below from NCBFAA regarding emails from 3rd party vendors to sell the conference list – these are NOT sanctioned by NCBFAA.  The emails stated:  Are you interested in purchasing an updated NCBFAA Annual Conference post show attendees list? You can get a custom built list at an affordable cost. This list […]

QUESTION: Our Company has several agreements to distribute electronic test equipment which is manufactured in France and sold by us within the North American Market. Our procurement department will place the order to the France based Manufacturers at our Contractually Agreed Discounted Rate from the normal list price. Often our Sales Department will request that […]

QUESTION: We will be shipping goods to our AU entity who will then sell the goods to the end customer.  The intent of the US parent company is that only 5% of the total profit remain with the AU entity. The current plan is that we will adjust the finances with either an internal debit […]

QUESTION: Here is the Debate:  How did your Trade Compliance team interpret the CBP Frequently Asked Questions [FAQ]- Guidance on Marking of Goods of Hong Kong – Executive Order 13936? It seems ridiculous that CBP is actually instructing us to have goods marked Country of Origin China, and the documentation[invoice, and entry] Country of Origin […]

QUESTION: Can any of our ICPA members provide information about what regulations that apply to importing polyurethane foam from Canada ?Our buyer has not provided information as to whether the foam will be in sheets, rolls ……..I have to believe that there is a formaldehyde emissions issue. So, I am guessing that there are EPA […]

QUESTION: Any recommendations on how to make sure that the Customs broker has actually filed an entry and paid the duties.  We received several penalty notices recently for failure to file timely and for late payment of duties from January. Although the broker is paying the penalties we need a way to monitor this.  Can […]

QUESTION: Future Planning Trade Activity: US Entity will be DEA registered as a Distributor & Exporter of various Controlled Substance (Schedules I-V) commodities US Entity will sell and ship DEA Controlled Substance (Schedules I-V) commodities, directly to a Puerto Rican Customer Assume goods (by Schedule B code) are greater than $2,500 US selling entity will […]

QUESTION: I presume that some members import lamps and other electronic devices.Our company has required testing the final product, but suppliers are complaining that it costs $10,000 and is not necessary.Our buyers are getting some heat about this. QUESTIONS: Is UL testing for lamps and luminaries required for the complete final product, or is testing […]

QUESTION: Can other ICPA members that import into LATAM and South American countries advise on the mandatory language for commercial invoices? Do commercial invoices have to be translated into Spanish?  I thought under WTO rules that English language commercial invoices were accepted in lieu of Spanish language invoices. How about with Brazil and other Portuguese […]