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 […]
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 […]
