Miscellaneous

MISCELLANEOUS

  • BOM AS TECH DATA

    QUESTION: Taking the definitions of technical data and technology into account, is a bill of material (BOM) consisting of part number, description and quantity considered technical data and/or technology? =========== Answers: My understanding from DDTC is that this is not “technical data.” George Tuttle IIILaw Offices of George R. Tuttle, A.P.C.1100 Larkspur Landing Circle, Suite […]

  • US owned returnable containers disposed of in Mexico – taxes due?

    QUESTION: US company owns returnable containers used to ship product to a customer in Mexico (customer handles the export and import).  The program has ended and the containers are no longer required (obsolete).  The containers are at the customer’s facility in Mexico.  Customer states there would be importation taxes due if they dispose of the […]

  • 5106

    QUESTION: We are trying to understand the 5106 requirement.  If another entity is the importer of record, but we are only the recipient and not otherwise involved in the transaction, are we still required to submit a 5106 form?  A client shipped some of their own materials to us from a foreign location via a […]

  • Textiles, soaps and apparel from Syria

    QUESTION: I am in the “creative” space.  I am artist and in addition to painting I buy, import and export art supplies etc. I was at an event this weekend at which some reps from a large Intl NGO were in attendance.  They were discussing all of the neat artsy, hand made things they were […]

  • ROYALTY SCENARIO

    QUESTION: A US company and a China company sign an agreement to create a joint venture.  At import into the US of finished product built in China using the US know-how transferred to China to make the parts has a Royalty.  The China company will pay the US company a royalty for each part sold […]

  • SECONDARY RELATIONSHIP RISKS IN FOREIGN TRANSACTIONS

    QUESTION: A US company wholly owns or partially owns a China incorporated company that does business with a China company who does business with Iran. No US dollars, no US person, no US content is involved in any transactions. Similarly, A US company wholly owns or partially owns a Russia incorporated company that sells EAR99 […]

  • MONTHLY NEWSLETTER TOPICS

    QUESTION: I’d like to hear what topics you include in your internal trade compliance/operations newsletter and how frequently do you send out to your team. I want to start a quarterly newsletter that includes bite size news, FAQs, recognition, upcoming events, project updates, new SOPs/procedures, policies. Any other suggestions or feedback? ***************** Answers: It’s not […]

  • SOP’s for Lithium ION Battery Shipping

    QUESTION: We are a company that does not make electronics but does occasionally ship computer equipment. Our Question is does anyone in the membership have an SOP they provide to their various shipping groups in regards to the regulations and restrictions on how to ship these items and what is said in this SOP?  If […]

  • Baltimore Port Direct Contact Details

    QUESTION: Can someone in the membership provide the contact details for the Baltimore port director and assistant port director; name, phone and email ========== Answer: All port details and contacts  are available on cbp.gov. ==========

  • Duties on Inland cost at the origin

    QUESTION: Current scenario: The product is being bought on EXW factory door Incoterms. The shipper arranges pre-carriage to the port and then bills us for pre-carriage on the Commercial Invoice. Pre-carriage charge is listed on the Commercial Invoice as an item line: Product cost – $ Inland Freight  – $ Question: Would Inland Freight be […]

  • Letter to extend liquidation date

    QUESTION: Our US import broker indicates that requests for extension of Entry liquidation dates (due to Sec. 301 exclusion issue) cannot be filed in ACE, and that we must write to the CEE requesting extension of liquidation dates. Does anyone have a format/template for writing to the CEE requesting extension of our liquidation dates, due […]

  • Customs requirements on Unit of Measure

    QUESTION: Have you been or know of a company that has been penalized by the CBP for incorrect UOM on entry summary?  Not related to duty draw back. We are constantly seeing import shipments that shows no weight of a part. We are not provided with the packing list. So, my broker is “prorating” the […]