QUESTION: It’s been some time since I’ve been involved in preparing documentation for an export shipment. With that said, many years ago we sent all invoices and documentation electronically to a customer’s broker instead of with the truck carrier. Upon joining my newest company, I’ve been told all documents are sent WITH the physical shipment […]
QUESTION: Can anyone tell me the definition of “agent” in the context of 15 CFR § 30.6(b)(2) Intermediate Consignee? Would an agent be a buying or selling agent, distributor, export agent? What is the role of an agent? 15 CFR § 30.6(b)(2) Intermediate Consignee – The name and address of the intermediate consignee (if any) shall be reported. The intermediate […]
QUESTION: From this week’s Federal Register Notice, “CBP has clarified in Headquarters ruling H045695 (October 15, 2010) that classification at the six digit HTSUS level does not constitute customs business. In addition, classification at a level lower than six digits, such as the four-digit HTSUS level, is not considered customs business either. Even though CBP […]
QUESTION: Our company is now bringing customs compliance in-house, and we are aware that the rule of thumb is to audit approx. 10 – 12% of our entries. I would like to set up a good cadence for monthly audits, but can’t seem to find a good template/checklist. Would any members possibly have an audit […]
We recently sold off several of our U.S. entities. I asked the Customs broker (the same broker will still be used) to transmit a 5106 change to the new address. All but one went through. The one that did not go through came back with a message that the importer# (the EIN) is frozen and […]
Players: Company A – USA Seller Company B – China Vendor producing product for Company A Company C – Canada Buyer, IOR Scenario: A takes the order from C, product is made by B Product is shipped directly from B to C The product does not cross US border. Question: Who pays Canadian Tariff; […]
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 […]
