QUESTION: Hi all. Curious how the members ensure they do not have forced labor in their supply chain, and how far they go to do so. Other than getting a confirmation with signature on a C-TPAT questionnaire , and having occasional surprise visits to the factories, is there anything else we should be doing? How […]
QUESTION: We own a joint venture in a non-US country at 51%; the remaining 49% is a registered resident company that has a parent that is also registered as a corporation in the non-US country. Our collective JV company is 100% registered in the foreign country as a unique entity with the aforementioned ownership split. […]
QUESTION: We just had a resolution on a prior disclosure, but I am having trouble determining how long I need to keep the documents involved in the disclosure. Is it the typically 5 years, so 5 years from today? Or do we need to keep them indefinitely? =========== Answer: 19 CFR 163.4(a) says, “Except as […]
QUESTION: My company exports agricultural fertilizer to Europe and South America via vessel. Either we charter the vessel or the customer charters the vessel. In this case the customer chartered the vessel. Because they are a foreign customer from Switzerland we were the USPPI so we filed the EEI. We allowed them to cut their […]
QUESTION: I am trying to get our public company set up on Periodic Monthly Duty payments, but our finance team (and bankers) think the program is a violation of Sarbanes Oxley Compliance. I know it is not because so many other public companies use the feature, but is there any materials or literature that specifically […]
QUESTION: I have read and re-read the ENs for Section XVI, Chapter 84, Heading 8421 and am confused. What does this mean: Section XVI General Notes (II) PARTS states, general, parts which in themselves constitute an article covered by a heading of this Section (other than headings 8487 and heading 8548) are in all cases […]
QUESTION: What source (no service provider information please) would you recommend to learn about types of control for Technical Data. We are commercial company and often need to work with ITAR data, however when data comes as CUI, FOUO, with references to DFARS, we are struggling to navigate these levels of control. I am curious […]
QUESTION: My company is considering hiring a DACA engineer who has been working for us as a temporary employee. We manufacture goods that are controlled by Commerce and State. Although the DACA employee will only work on commercial projects (EAR99), I would need to apply for export licenses to prevent deemed exports in case he […]
QUESTION: Both Company A and B are US entities. Company A imports metal part to US from China (COO = CN) and drop ships to Company B Company B paints the metal part and ships to Company A. Company A uses metal part in assembly/manufacturing processes into a larger article. As there is no substantial […]
QUESTION: As the USPPI involved with routed export transactions I am hitting some brick walls when it comes to recordkeeping. Am I correct in stating that I need to have and keep a copy of the Bill of Lading and proof of AES filing? I have started to ask the freight forwarder for these copies […]
QUESTION: My Logistics department has used the wrong schedule b on shipping invoices a few times this past month. All of the shipments so far, have been under $2,500, are EAR99, and do not require filing luckily. I am in the process of implementing corrective action internally, but as far as the shipping documents themselves […]
QUESTION: We are exporting equipment (heading 8422.30) from the Netherlands to our new customer in South Korea. Our equipment is loaned only, not sold so the invoice value will be for customs only not for the customer to pay us. Is there another way to import loaned equipment so the customer doesn’t have high duties […]
