QUESTION: Our company makes hardware mostly for professional audio applications. The hardware is available for purchase through the company but mostly through distributors worldwide. There is also some multimedia applications involved and, therefore, some software and firmware. The software and firmware are classified as EAR99 – NLR, and subject to the EAR. The software is […]
QUESTION: We are benchmarking our internal trade compliance audit program and would appreciate any input on what companies use for audit frequency (how many years between audits) and if there are any metrics such a $ threshold and what are the annual targets for total audits completed in a year (% of sites audited, % […]
QUESTION: I’d like to ask the membership if as IOR whether CBP4811 is actually completed and sent to CBP or is broker allowed to declare at time of entry or is Broker allowed to determine this ========== Answers: A 4811 is kind of like a limited change of address form notices, bills or refunds. Without […]
QUESTION: Anyone from ICPA membership is familiar with the process of importing non-NIOSH approved respirators and protective/surgical masks from various manufacturers in China? Is there any restrictions /requirement during the importing process? Anyone heard about “Whitelist”? What is the process to have medical device listed on Whitelist? Appreciate your comments and suggestions. ***************** Answers: Short […]
QUESTION: We have recently been told by a major steamship line that it is policy that they can only invoice the “Invoice company” listed on the B/L. Our company name appears as the notify party only. The carrier terms and conditions state in part, the following” “Every person defined as merchant in clause 1 shall […]
QUESTION: We would appreciate assistance from the membership if anyone has a checklist of the requirements for importing from China, No Touch Thermometers. Due to Covid-19 this is a rush order request-A lot to research in short time. Understand the thermometers are regulated by FDA – FDA Cosmetic Act They are a medical device – […]
QUESTION: Is anyone actively implementing/utilizing the Broker Known Importer Program (BKIP)? If so, are you seeing tangible benefits? ========== CBP is not actively using BKIP in their targeting algorithm so the flag is not impacting their decision on whether to inspect the goods. BKIP does, however, provide some best practices for importer identification/validation which will […]
QUESTION: Our company is in the process of selecting an ERP. Can the ICPA community provide guidance on the types of questions we should ask regarding Trade Compliance and Logistics modules, capabilities and functionalities? What are the minimal data cells and info should the ERP have? Can anyone provide insight into the benefits that integration […]
QUESTION: Situation – we purchased a machine of Chinese origin for our Mexico facility. It was moved under a TE and arrived to our brokers bonded warehouse yesterday. We just got word that the MX government may shut our Mexico operation down because it is considered a non-essential activity. The machine is subject to Section […]
QUESTION: If a broker has a DBA issued by a state or county within a state, can the broker apply for a National Permit and then make entries outside that jurisdiction? ================================================================ Answers: Apples and oranges. No reason why you can’t. ================================================================ Are you an individual with a brokers license? Have you already filed for […]
QUESTION: Does anyone have experience working with external customs advisors during an audit? Interested to know if you sign an engagement letter of some sort. How do you define the scope of their work in an audit? Sometimes these things can take turns here and there. Is it appropriate to request a weekly or monthly […]
QUESTION: Is there a resource in place that identifies classifications for Covid-19 related articles? ========== Answer: Attached is an updated classification guide for COVID19 Supplies https://www.icpainc.org/wp-content/uploads/2014/10/COVID-19-supplies-hs-classification-reference_en-1.pdf ===========
