QUESTION: The 32 FAQ’s regarding Venezuela do not directly answer these questions. Seeking help from the members: Regarding the recent changes in export law to Venezuela, what is the likely correct answer to the following: Product “A” is not military at all, no dual use, completely civilian, EAR99, but Product “A” [a fully automated pallet […]
QUESTION: 3 scenarios. Facts as follows: US Company “A” sells to Europe company “B”. No OFAC sanctions in place on company “B” AND Company “B” is not owned in aggregate of 50% or more by OFAC sanctioned entities. Company “B” places a PO to company “A” and in the PO instructs company “A” to ship […]
QUESTION: Our US company will be leasing manufacturing equipment to a manufacturer in Thailand. The equipment will be used to manufacture a product for sale within Thailand and to other countries. The manufactured product will NOT be exported to the US. Our US company will receive a royalty off the sales of this Thai manufacturer. […]
QUESTION: Can someone confirm that if the export consist of only EAR99 and NLR, the export is exempt from the EEI filing change on 6/29/20? %%%%%%%%%% ANSWERS: Below is a reply we received directly from BIS’ Regulatory Policy Division: QUOTE Please review the guidance that BIS has provided on its website at https://bis.doc.gov/index.php/all-articles/2-uncategorized/1686-revisions-to-eei-filing-requirements-pursuant-to-revisions-to-section-744-21-china-russia-venezuela-military-end-use-end-user-rule. Per the […]
QUESTION: With the new EEI filing requirement for all shipments to CN, VE and RU regardless of value, I’d like to know if anyone in the membership has knowledge that the main small pack express carriers have had their shipping software updated to accommodate the new export filing requirement where it will raise a flag […]
QUESTION: Can a foreign entity apply using BIS Snap-R website for a US export or re-export license ? where in many cases, BIS require attach drawing or technical specification of controlled items, can be considerate a deemed export? =========== Answers: Anyone can submit the application, but they must be in the United States at the time a […]
QUESTION: If an HTS specifically says “put up in forms or packings for retail sale” can you only use that HTS when it will be sold at retail? Or is it more referring to the format? For example, if our company is importing an item for our own use but it’s the same packaging format […]
QUESTION: What are the ramifications if a company has a Freight Forwarder that is exporting goods for a company but the USPPI ID does not equal the USPPI name and/or the address? I’m would assume these are all routed transactions but they are not all flagged that way in the AES-202 report. %%%%%%%%%% ANSWERS: Unclear […]
QUESTION: Would anyone in the membership be willing to share a checklist for a sales team that would uncover any potential customs or logistics issues a product might have before the fist order is placed that wouldn’t be surfaced for other processes. Looking for a something general . Some of the items would be lighting […]
QUESTION: We have been notified by a customer that they had a Cyber security breach and some of our data has been involved. They have provided us with a BIS case number, but no details regarding which data was compromised or to whom it was released. Is there a legal requirement for the customer to […]
QUESTION: Is a Test Plan that is required for testing and includes specific instructions for an End-Item enumerated in the ITAR considered technical data. ========== Answers: Since you are providing a defense service, per section 120.9 (testing), you are handling technical data, per 120.10 (definition of what is considered technical data). In short, the answer […]
QUESTION: If you have a generic COO certificate stating that your vendor produced a product in the US, CA or MX but it’s not on a USMCA form, can you use that COO to justify that product qualifies for USMCA or is considered originating material for USMCA analysis of your part? =========== Answers: A good […]
