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 […]
QUESTION: Since ruling HQ 115278 was published in November 2001, have there been any updates? Can a licensed customs broker employed by one entity, file on behalf of other entities? It appears there are 3 options: 1) The LCB would have to become an employee of each subsidiary; 2) a separate customs brokerage business would […]
QUESTION: Our freight forwarder is saying a number of their clients combine multiple different vendors onto one bill of lading in an effort to reduce CHB clearance costs. In this practice the freight forwarder is listed as the shipper on the B/L and the actual shipper information is listed in the body of the B/L. […]
QUESTION: It would be interesting if ICPA members, placement firms and others could share of best practice for reporting lines of warehouse, shipping and receiving staff. Do these positions report up to Supply Chain, Logistics, Operations? ============ Answers: We don’t have a Logistics department, therefore, warehouse, shipping and receiving staff report to Operations. ============ I […]
QUESTION: I am wondering, how many companies have a formal OFAC Sanctions Compliance program document that they publish, post and train against? I am not talking about having all the requirements covered in one way or another (screening, training, risk assessment, etc. conducted by various teams or departments) or having a policy statement or document […]
QUESTION: We would very much appreciate the membership feedback to this situation. We are working to set standard incoterms with our non-North American supply base and have a debate if FCA Supplier’s Dock or FCA Origin Country’s Port of Export is more appropriate. (Wuxi, China vs. Shanghai POE for example) Referring to this FR as […]
QUESTION: I sell EAR99 items to Huawei from a non-US location, hence the FDPR G.P. 3, but these items are not directly used to make Huawei products. What I sell are items for supporting the building within which Huawei makes products that are now controlled. Because my items are EAR99, no Huawei components are installed […]
