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 […]
QUESTION: My company is doing a pilot program for self-filing via AES Direct. We are currently not set up to issue Chamberized COOs as this is currently done by our Freight Forwarders. There are thousands of Chambers of Commerce and various online services. My dilemma is that my company belongs to many Chambers of Commerce. […]
QUESTION: What would you expect your Global Trade Management System do for you? =========== Answers: Restricted Party Screening that receives and sends data with my ERP system; tariff classification with the ability to create decision trees and including CROSS rulings and explanatory notes and updates my ERP system; free trade agreement qualifications; export and import […]
QUESTION: Our finance team is discussing whether it should follow the Average Cost or Standard Cost costing method. Does this decision have an impact on the customs valuation for imported or exported product? If so, please explain what the impact is and which costing method should be used for imported and exported product. ************** Add’l […]
QUESTION: I was told that our company has a stamp from our Chamber of Commerce so that we can stamp our own export documents when requested by the customer. Is this valid? My understanding of the Chamber stamp signified that the Chamber as a third party reviewed the documents to for completeness and certified them. […]
QUESTION: Looking for HTS classification assistance here- for EU and US The plan is to purchase and import material that was extracted from a plant and subsequently refined and purified. This would be classified in Chapter 13. This material has also been granted a CAS number. When searching for the CAS number for the chemical substance in the […]
QUESTION: I was wondering if anyone in the membership would be willing to share how they collaborate with their sales team to ensure export control and licensing approvals are in place before an order is entered in their ERP systems. One of the major struggles I have experienced is the disconnect between Sales, Compliance, and […]
QUESTION: I have been discussing with my colleagues in Reg Affairs the difference between the phrases “approved for use in a market” and “approved for importation into a market”. By approved for importation, I mean industry registrations (USDA, Min of Health, FDA, FCC) or special documents to accompany a shipment or specific data that needs […]
QUESTION: When the regs dictate that I must be able to produce records in a “timely” fashion, what exactly does that mean? It can’t mean immediately or instantly, right? A few hours or a day should be adequate? *************** Answers: Great question! There is generally a rule of reason applied here. CBP’s recordkeeping ICP provides: […]
QUESTION: Can anyone share a sample Anti-Diversion Clause to put on an export invoice? =========== Answers: These commodities, technology or software were exported from the United States in accordance with the Export Administration Regulations. Ultimate destination (insert country). Diversion contrary to U.S. law prohibited. ========== Even if you are shipping EAR99 items and its not […]
QUESTION: Our company markets an oil for topical use. The exact same product(s) is also marketed and labeled differently for a culinary use. If one were to export these two products (labeled for their respective uses; one topical and one culinary) would it be under the same HS classification for essential character or it would […]
