QUESTION: If a tariff exemption has a specific FOB price criteria (i.e. price must be more than $.35 and not to exceed $2.00) is there any regulatory issue with negotiating pricing adjustments with vendors to increase and/or decrease the price of those subject items to allow the product to fall into the exemption range? The […]
QUESTION: My company recently had shipment impacted by CN tariffs (roughly $35k) get lost in transit after clearance. The vendor did not package the shipment in accordance with carrier guidelines and half of the items were lost. The carrier has communicated that an extensive search was performed w/o resolution, so a replacement was ordered, which […]
QUESTION: I believe I truly understand what a routed transaction is; however please would you confirm that the transaction is still considered routed, due to the FPPI appointing a US forwarder to facilitate the goods out of the US, even if the USPPI files in the export system and not just when the FPPI’s US […]
QUESTION: Have a question regarding returns back into US. If a customer is returning US Manufactured good and being return back to the manufacture/seller; in order to claim 9801 the only documents required is US manufacture Affidavit and Foreign shipper declaration right? Or is there anything additional you have to provide. In these cases returns […]
QUESTION: If your company organizes events such as conferences, seminars or webinars, do you screen attendees against Denied Party List? If you do – do you screen attendees or invitees? If you do not screen applying concept of “open/unrestricted” conference, what factors do you use as a support of this determination. %%%%%%%%%%% ANSWERS: Yes, and […]
QUESTION: Nowadays, when we have constant additions to Entity List and SDN, what is the reasonable expectations for company for the timing of enforcement of new denials within internal systems? Depending on industry and nature of business(hardware/software/service) company may maintain different frequency of sales/engagements and database flagging, but overall I am curious to understand what […]
QUESTION: Hi everyone. We have a question about the potential importation / shipping of LED flashlights. Various products fall under the following HTS Codes: 8513.10.2000 – Flashlights 8513.10.4000 – Flashlights: Other 8513.90.2000 – Of Flashlights There is a question regarding transportation / compliance requirements if these are shipped with or without batteries (alkaline is the […]
QUESTION: I just got done review the OFAC N Korea sanctions. It appears that they do NOT apply to foreign subsidiaries/majority owned foreign joint ventures of US companies (like several other sanctions programs). 510.326 definition of US Person does not include foreign subs. So it appears that foreign subs of US companies are not subject […]
QUESTION: We are a U.S. company with 5 divisions working on our document that communicates information on sanctions, screening and antiboycott Want to ask the membership: • How you communicate this information and requirements? Via a corporate policy? Via corporate guidelines? Other? • How long such a communication is? • How updates are communicated and […]
QUESTION: We are setting up a new solution to file imports entry and entry summary with CBP and have a question on exchange rates to be consumed. Our supplier (exporter) provides invoices in non-USD currency and hence we need to bring in the exchange rates from cbp. However, the cbp site has exchange rates in […]
QUESTION: I am seeking any best practices the membership may have regarding drop shipments from China (or any foreign country) shipping direct to customers in the US. We are the importer of record (IOR) and would like to declare the (lower) transaction value between us and supplier in the foreign country upon import into the […]
QUESTION: Can anyone share a good definition of technical data that would cover both EAR and ITAR? We are trying to educate a broad range of non-trade stakeholders how to identify when they are dealing with technology/technical data, as part of export compliance awareness training campaign. We want to make sure that people understand both […]
