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 […]
QUESTION: I have a field service engineer who is trying to ship their company-owned tools back to the U.S. from overseas. In order to claim 9801.00.8500 for tools of trade, do the USHTS classifications need to be declared to customs as well? My customs broker said that the classifications might need to be declared on […]
QUESTION: I know that Libya is a country of concern but we don’t currently have a full embargo for EAR controlled goods or OFAC, but it is listed as a targeted sanctioned country. Does anyone have any experience with this country? Is there anything I should be aware of in case I opt to do […]
QUESTION: Can someone please explain the process for transmitting a DSP-61 when you are importing an item using a Carnet since an actual customs entry isn’t filed thus no way to electronically transmit the PGA dataset for the license? ************** In this case, your ‘entry’ record is the carnet importation counterfoil (signed/stamped by Customs); however, […]
QUESTION: I have been informed by an European exporter that on Dec 24th, 2019 SASO has announced that starting from Jan 1st, 2020 all items imported in KSA must be mandatorily labelled with barcode. Anyway it appears that SASO hasn’t yet indicated how this barcoding should be implemented, does anyone has any additional info on […]
QUESTION: Can we use blanket end-user certificate? Does anyone doing that instead of asking for each shipment? Most of our shipments are intercompany and same products with same ECCN. **************** Answers: Sure – I allow this for high volume/repeat orders and the maximum period of validity is one year. SO instead of referencing a single […]
QUESTION: A recent question to the membership centered around Restricted Party Screening and determining an appropriate “% match score” to search for potential hits, or matches, to a company’s list of vendors/customers. When we set our parameters to look at potential hits with a 95% match, we get lots of hits with names that are […]
