QUESTION: Anyone familiar with importing OTC hand sanitizers? ************ Answers:I’m currently advising clients on this. Hand sanitizer is considered an over the counter (OTC) drug by the FDA. There are rules regarding ingredients and what the labels and marketing can say. I’m a Customs lawyer but am working hand-in-globe with my FDA lawyer partner on […]
QUESTION: Does anyone in the membership have a “No SLI” policy? My management would prefer that we issue no SLIs, and have our approved customs brokers file EEI and then provide the ITN to the shipper. Do you have a written policy I could see? “In the event an SLI is requested, please forward request […]
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 […]
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 […]
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 […]
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 […]
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 […]
