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 […]
QUESTION: We have a four party transaction. Manufacturer A (US) Sells to Related Company B (EU) who sells to Company C (EU) who sells to Ultimate Consignee D (ME). The forwarder is arranged by Company C. As the only US party, we understand that we are the USPPI and that our sales price to Company […]
QUESTION: Regarding the Section 301 tariff exclusions for “Face masks and particulate facepiece respirators, of textile fabrics (described in statistical reporting number 6307.90.9889)” – Does this included reusable face masks? =========== Answers: Yes. This is the HTS we are using. =========== 6307.90.9889 includes all textile face masks. =========== Add’l Answer: Exclusions regard SINGLE USE ONLY […]
QUESTION: How do others manage returnable containers/dunnage on their invoices/manifests/entries when they are filled with parts? In recent discussions with an Import Specialist we’ve been advised that every shipment needs to show the returnable containers and an associated value under 9803.00.50/Duty Free – Plastic Containers, IIT, Instrument of International Trade. In my experience, the containers/dunnage were […]
QUESTION: For those in trade compliance at global companies, you probably screen suppliers of merchandise/materials in addition to customers of your products and/or services. Do you also screen the myriad variety of service providers that you have around the world, such as, to cite a random example, vendors of cleaning services for your company-owned stores […]
QUESTION: We are trying to set up our company on ACH (mulitple divisions) .After sending form 400 and being asked for a 5106, all has been going smooth and the PUN was finally obtained for some of our divisions. We then continued to go one EIN at a time for the next batch of divisions […]
QUESTION: Does anyone know of a list that has an additional column, for the DEA regulated substance that may fall into said HTS and hence require reporting/permit? ******************** Answers: There is a list of HTS that “could” require DEA export permits or reporting; these flag in ACE when filing AES. https://www.cbp.gov/sites/default/files/assets/documents/2019-May/New%20Master%20DEA%20Drug%20Code-HTS-Schedule%20B%20Reference%20Table%2005012019.xlsx But it’s not 100% […]
QUESTION: How does non-US multinational companies managed Sanctioned Party Screening for employees as it relates to GDPR and privacy global and local laws? Do you have US dedicated plus global policy? Or perhaps the norm is not to screen while the US becomes the exception? Do you screen US employees? Thanks for sharing and for […]
QUESTION: The DECCS FAQ on the State Dept website states third parties who work with registered companies must have a unique email for each company they work for. In other words, you cannot use your same business email for multiple clients. What is a practical method to create all of the emails, within your business […]
QUESTION: Does anyone have a global temporary import procedure they can share? I realize it’ll have to be fairly high-level because of how different each country’s temp import regs are. %%%%%%%%%% ANSWER: Cannot share but consider the following as you put something together: 1) ATA Carnets – can be cumbersome and penalties apply if you […]
QUESTION: This question is targeted to those in industries that have dealers, and distributors in foreign markets, particularly in China. We, the parent company, have related party transfers between distributing entities in foreign markets. All of our intercompany distributor agreements state that the distributor is responsible for all warranty costs incurred in the country, therefore […]
