Miscellaneous

MISCELLANEOUS

  • Customs Business – Vessel Manifest Confidentiality

    QUESTION: Would submitting Vessel Manifest Confidentiality request to CBP be considered “customs business”? I need to submit this request for our 5 divisions operating under different EINs. %%%%%%%%%% ANSWERS: I believe that is. I have done it in the past. It is a very simple procedure. %%%%%%%%%% Probably not; it likely doesn’t have anything to […]

  • AUTO E-MAILS FROM SNAP-R

    QUESTION: Just curious if any of the members who use SNAP-R are experiencing the same issue in that the system is not sending any emails. The last one we received was April 17th. We missed a request for additional information on one of our applications from the L/O as well as the acknowledgement emails and […]

  • Classifying as a consultant

    QUESTION: Does the membership have any suggested language when providing item classifications as a consultant? “Results are provided as informational only. Importer/Exporter is solely responsible for the accuracy of the information filed in customs clearance documents.” Something like that. We’ll be providing both ECCN and HTS US classifications. %%%%%%%%%% ANSWERS: You may also want to […]

  • IN-BOND MOVEMENTS

    QUESTION: Do goods moving in bond in the USA have to be stored in a customs bonded warehouse, or can they be stored anywhere as long as they are exported within the 15 day requirements? For example, shipments moving from Canada to Mexico…the CARRIER has to be bonded for the goods to move and the […]

  • LIC. EXCEPTION STA

    QUESTION: If a company is confident the product is eligible for the STA Exception, do you have to request a License Exception STA confirmation thru SNAP-R? *************** Answers: No, if you are confident your company can use License Exception STA, you do not need confirmation from BIS. It is important to follow all of the […]

  • COMMUNICATE TRADE SANCTIONS

    QUESTION: Checking how members communicate company policy on complying with trade sanctions.Looking to understand whether a policy document includes specifics by country that is updated as necessary, government links in lieu of specific information or something else. Would greatly appreciate any examples of policies. ************* Answers: In my trade compliance manuals I typically call out […]

  • Delivery Verification Certificate

    QUESTION: We recently imported some goods from supplier that included a Dept. of Commerce “Delivery Verification Certificate” form. Their government, Denmark, is requiring that this form be completed by CBP as proof of importation. I haven’t ever seen this form before so I reached out to my CEE and provided them copies of the entry […]

  • Regarding SASO Packing Regulations

    QUESTION: Are there any further packing regulations for shipments going to Saudi Arabia other than everything must be on pallets? %%%%%%%%%% ANSWER: Plastic packaging material needs to comply also. https://www.saso.gov.sa/en/Certification/Certificates_of_conformity/Pages/Registration_of_plastic_products.aspx ================================================================

  • Foreign customs audit – request for cost information

    QUESTION: We are undergoing an audit in NL. The Customs Agency wants to review the Transfer Price and the TP methodology at which we sell our products to related parties and the price we sell our product to unrelated parties in NL. They asked our consultants in NL to have us (in the USA) provide […]

  • MTB

    Add’l Answer: You can hire counsel if you like spending money. But if your product meets the requirements listed in the MTB, you are allowed to claim the MTB. We claim a MTB which we did not request, I reviewed the provisions, checked off the boxes that it qualified and then I informed our Account […]

  • Algeria and Morocco

    QUESTION: I understand that these two countries do not allow ex works shipments (out of the US), has anyone heard the same thing and is there any basis for this? Thanks ! ========== Answer: I’ve never heard of any country ‘not allowing’ ex works shipments. There could be logistical challenges and you have to arrange […]

  • Doing business with Huawei

    QUESTION: I have a question regarding the Huawei restrictions. If we are an American Based and owned company can our locations in foreign countries do business with Huawei if the items do not come into the United States ========== Answers: The restrictions include re-export of items/technology covered by the EAR, so – it depends. Depending […]