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 […]
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 […]
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 […]
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 […]
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. ==========
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 […]
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 […]
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 […]
QUESTION: If you were teaching (or taking) a graduate level course that covered Customs. What topics would you want to see covered? What do you wish you had learned about trade compliance and operations in school? =========== Answers: I’ve actually put together a syllabus and curriculum on this topic. It depends on what you want […]
QUESTION: In order to request a classification ruling, it must concern a “prospective” shipment. What does “prospective” mean, in that sense? I just want an official ruling on what to classify something I produce. =========== Answers: Simple: not yet imported. =========== Read 177.1(a)(1) and 177.1(a)(2)(i) and (b). Here is 177.1(a)(1) – A “prospective” Customs transaction is one that […]
QUESTION: Do any team members have a Global Procedure in place to review import and export declarations that they would be willing to share? The challenge faced is how do we develop a Global Procedure that can be applied to all without creating a cumbersome process for the larger locations. Additionally, interested in where you place the […]
QUESTION: We are being asked to ship EAR99 equipment items to the U.S Military Base in Guantanamo Bay, Cuba I have found the BIS License Exception CFR 740.11 for U.S Govt Agencies (GOV) but after checking OFAC website and 31 CFR 515 Cuban Assets Control Regulations cannot find any evidence of an OFAC License exception […]
