Miscellaneous

QUESTION: Does anyone have an encryption questionnaire they are currently using and would like to share? I’d like to compare what we have. %%%%%%%%%% ANSWER: Hello, Attached is the ENC Questionnaire that we are using to classify encryption products. https://www.icpainc.org/wp-content/uploads/2014/10/2019-Encryption-Questionnaire-Template.pdf %%%%%%%%%% This is how we used to do it back “in the olden days”, but […]

QUESTION: I recall seeing a poll somewhere that in the last 10 years Trade Compliance has been making a move out of Supply Chain and into other departments. Looking for the membership to share how they’ve been able to get Trade Compliance OUT of Supply Chain and into Legal, Audit, Finance, etc. What arguments did […]

QUESTION: We have a routed transaction and there is a valid POA on file between the FPPI and their US forwarder. The FPPI provides authorization to their forwarder and to the USPPI that says the AES filing can be made under the USPPI’s EIN number instead of the FPPI’s. This “authorization” circumvents the need for […]

QUESTION: We hired someone for a US compliance role, US Compliance Specialist. Advised verbally that the role would “support” other import sites globally. This global support and activity was never put into the job description. This US compliance role has evolved to spending more time on the other sites in other countries. The title was […]

QUESTION: What is the benefit of using one of these zones in Jordan for importing into the US to receive duty-free treatment, if the goods still need to have 35% local value content just as they would need in any event to qualify for duty-free treatment under the the Jordan-US FTA? ========== Answer: For clarification, […]

QUESTION: Our US Customer would like to place an order with our US Company for goods that can only be produced in our GB facility (the customer is the design authority not my company). They would like us to order it from GB and have it turned over to their freight forwarder to handle the […]

QUESTION: We manufacturer an EAR99 scientific device that will be incorporated by a foreign company into a large research system to be sold to someone on the Entity List. The value of our component is <10% of the total value and is not listed on § 734.4 De minimis U.S. content exclusions. At first, I […]

QUESTION: Have had a couple inquiries from our German customer asking for a chamberized certificate of origin. We understand that such a form is not required to import our goods to Germany, rather the customer is asking for it since their middle east customer needs it. (so not a drop shipment from the US to […]

QUESTION: Products sent to Mexico to be repaired, once products are repaired they are shipped back to the US, imported under 9802.00.40. My question is how would these be reconciled based on note 3(d) of heading 9802 products that are country of origin China, but repaired in Mexico. (d) For the purposes of subheadings 9802.00.40 […]

QUESTION: For anyone that is participating in the HOPE program (Haitian Hemispheric Opportunity through Partnership: How/where to start? What are the requirements as for as record keeping? How do we prove to CBP that we are importing goods that are HOPE eligible? ========== Answer: For recordkeeping would be similar to any other type of Special […]

QUESTION: What are my compliance risks and responsibilities if one of my customers/ suppliers appears on the World Bank Listing of Ineligible Firms? Is this a list I need to screen as part of my overall global DPL screening efforts? ========== Answers: Good question. I would consider this a marginally relevant list for US companies, […]