QUESTION: A company that we have exported to in the past is now on the BIS Entity list. The FR notice indicates that they will “impose a license requirement for all items subject to the EAR and will exercise the license review policy set forth in subpart (d) of EAR sec. 744.2, a nuclear end-user […]
QUESTION: What is the membership seeing or hearing from our government agencies on future or existing export controls for telematics and autonomous technology that can be installed on vehicles or construction equipment? This technology is moving so quickly and is difficult to keep up with or even distinguish if it could be under export controls […]
QUESTION: In the past, when have received US Customs refund checks (Post-Nafta, Protests, PEA’s, etc) – they have always arrived with a lower portion of the check (i.e. stub); this contains vital information such as Broker filer code, Customs entry #, etc – that we need to be able to trace back to why we […]
QUESTION: Our company will be doing a Buy One Get One promotion and I would like some guidance on how these should be shown on the commercial invoice for export. Some offers are buy one and get a second of the same item free, while others are buy item X and get item Y for […]
QUESTION: Hope that the membership can provide some clarification on the following FR from 8/26/2019. : 84 FR 44671-44672: Imposition of Additional Sanctions on Russia under the Chemical and Biological Weapons Control and Warfare Elimination Act. The section I’m unclear on is section 3.”Further Export Restrictions” the below “Other Reasons for Control”. Are exports and […]
QUESTION: Does a carnet holder legally have to be the entity that is in possession or the owner of the goods being imported/exported? Is there a legal definition of carnet holder? %%%%%%%%%% ANSWER: A carnet is a passport for goods. To get duty free, temporary, entry into a country, the goods must be accompanied by […]
QUESTION: Can someone advise where in the regulations it states what is required by an importer upon receiving merchandise into their warehouse. Not section 19 of the regulations. I mean piece count requirements, record reporting shortages, overages for entry correction. ========== There is not specific regulation that requires you to do piece counts. accurate quantity […]
QUESTION: I have a wholly owned foreign sub in France. They intend to purchase Canadian origin material for supply to their customer in India and have obtained all appropriate licenses from the French authorities. The material would be NRC jurisdiction if US origin, however, there is no US product or persons involved in the transaction. […]
QUESTION: I am seeing a new job title pop up occasionally, at least in East Asia: Trade Compliance Executive. Does anyone have any background on this and an explanation of where it fits in on the usual Specialist-Analyst-Manager scale? ========== Answers: I think this is a VP level position which discusses escalations with Chief Compliance […]
QUESTION: Can anyone provide assistance regarding co-mingled fungible materials? Scenario: Origin of item A is US. Origin of item B is China. The A+B chemicals, which are commercially identical with the same HTS code, are mixed and stored in the same storage “tank”. The “tank” is then used to fill retail sized containers that are […]
QUESTION: Does anyone have thoughts on “care of” company names being used in your business partner addresses, in regards to Restricted Party Screening? Most Restricted Party Screening providers’ software screen the company name you input against names on the lists, then a separate screen of the address to addresses on the list. Hence I’ve been […]
QUESTION: We sell to a OEM in the United States items that they assembled into to a complete HVAC system. This company, located in the USA then sells this set of items/units that have been assembled, to Canada. The unit in Canada fails and replacement parts are required from us. Our client the OEM, contacts […]
