We have a situation where Customs has issued 9 bills to our company for an exclusion, they claim had expired on 5/31/22. However, the exclusion was extended through 11/30/22. We have sent the FR to our CEE proving the exclusion was extended. Of course, now that we have received the bills this means the entries […]
QUESTION: Seeking guidance on updating AES Filings related to a change in export authorization. Example is the transfer of articles originally exported under TMP to a permanent export with an approved BIS License. How does industry close the TMP in AES and transfer those items to a permanent export? Thank you in advance. *************** Answers: […]
QUESTION: Our parent company in Germany is considering purchasing some precious metal scraps from a German supplier, but there is some concern that some of this “mixed” metal scrap may contain scrap material from Iran. Where can I research to find out if secondary sanctions would apply here if they proceeded with the purchase? Or, […]
QUESTION: Are there any restrictions on importing polysilicon into the US? ***************** Answers:I would determine the HS Code and country of origin and share that info with my customs broker. I’d ask them to tell me if the country of origin and/or HS Code flag for any restrictions. ***************** Oh yes! Depending on where the […]
QUESTION: Can a forwarder mark-up broker fees if the grantor waives the requirement in 19 CFR 111.36(c), including its subparts and authorizes the forwarder to transmit its bill for services including brokerage charges and fees? ========== Answers: There is no legal authorization for “the grantor” to waive a Customs regulation. ========== A broker can charge […]
QUESTION: A U.S. company A purchases domestically widgets from a U.S. supplier B. U.S. Supplier imported the widgets from Foreign Supplier C. Foreign Supplier C is 50% or owned by an OFAC SDN. Is there any compliance concern for Company A if it has knowledge about the original manufacturer and its ownership? Company B I […]
QUESTION: CBP notified us that our company would be placed on sanctions due to an unpaid bill. However, they had cashed our check (and we had their endorsement) 3 months prior to this notification. Once I proved this to the CBP officer, he agreed payment was received, but required us to pay additional interest of […]
QUESTION: Can a company legally write off Customs duties and tariffs without a drawback process? **************** Answers: This sounds like more of an accounting question than an import compliance question. But my thought is that duties are an expense deductible from taxable income, and that drawback would be income to offset any deduction. *************** Companies generally […]
QUESTION: Is anyone aware of any trade restrictions preventing routing trucks through Russia? The product is not from a Russian company. It would only route through Russia. With the understanding that Social & security concerns are different subjects. ************** Answers: I am not sure what “ With the understanding that Social & security concerns are different subjects” […]
QUESTION: Can someone confirm who has authority to issue a commercial invoice? My company, in the US, issue’s a PO to our manufacturer overseas and then has the order shipped direct to our buyer who is in Indonesia. Our buyer advised Indonesia Customs requires the commercial invoice to be issued by the manufacturer since it […]
QUESTION: What is the best way to find out what penalties we’ve paid to Customs in the past without doing a FOIA? Would our brokers have the same knowledge? Would the surety companies have a list of what has been issued in the past? I just started at a company and am being told that […]
QUESTION: Items of NCV or FOC must be shown with value on the Commercial Invoice; however, do their total values have to be added into the total Commercial Invoice value at the bottom of the Commercial Invoice? %%%%%%%%%% ANSWERS: Yes, It is Customs Regulation that you start with the invocie value notated as I.V. then your […]
