Miscellaneous

MISCELLANEOUS

  • Technology transfer to Singapore

    QUESTION: We, a US company, purchased a German-owned company and all of their intellectual property including technical data that is controlled under the EAR. Currently manufacturing is only done in the US. We want to sell all IP and controlled technology to our Singapore branch, and begin manufacturing in India. Since currently owned by a […]

  • 9802/FTZ AND NAFTA

    QUESTION: Scenario: We are importing product made from in Mexico. The part we are importing has both 9802, NAFTA, and non-NAFTA components. Question: On our Entry are we able to break out all 3 components so that we can take advantage of both the 9802 and NAFTA duty free status for those components? ========== Answers: […]

  • LICENSED BROKER SUPERVISION REQUIREMENT

    QUESTION: An importer learns that their Freight Forwarder / Customs Broker no longer has a Licensed broker on staff in the local office. Can that local office still file Customs entries on the importers behalf, using the corporate office’s National Permit? ========== Answers: 5. Waiver Request for Qualifying Licensed Individual A waiver is a broker’s […]

  • HTS UNIT OF MEASURE ISSUE

    QUESTION: We have items that we have shipped for many years using schedule B: 6909.11.0000. This item is a very small ceramic ball that we sell by the lb. or Kg. Therefore, counting them as units is not an option. Until recently, we used X (No quantity required). Unfortunately, now that CBP has eliminated that […]

  • LICENSE FOR IRANIAN EMPLOYEE

    QUESTION: I have an non-US citizen/non green card Iranian citizen working at my USA company in the USA. He will now need access to AT controlled data. I have no BIS/OFAC authorization for him because it was not needed (EAR99 only up until now). Is it solely BIS that I have to obtain a license […]

  • Brokerage permit requirements

    QUESTION: I do business with a Customs broker in our local city. The broker is headquartered in another city within the state and has a national permit. I just found out this week that the only Licensed Customs Broker in the local city office resigned. Can I still have this office file our Customs entries […]

  • FOB reductions for late shipments

    QUESTION: I’m interested on how other members handle FOB reductions and/or air freight charges when a shipment is late, and the vendor is covering the air expense. We’ve done FOB reductions for years, but am being challenged for another way to handle the air freight expense, other than reducing the FOB price. I am looking […]

  • USE OF ENC

    QUESTION: Is a CCATS required to use ENC? How do you know if the supplier’s classification is sufficient? =========== Answers: A CCATS is not required to use ENC. You don’t know if the supplier’s classification is correct, that is why we never rely on a supplier’s classification. ============ No, a CCATS is not always required. […]

  • Time allowed to tender duties

    QUESTION: Under 19 U.S. Code § 1592(c)(4) and 19 C.F.R. § 162.74(c), CBP has the discretionary power to extend the number of days when an importer must tender duties, taxes, and fees as it relates to perfecting a prior disclosure. Has anyone from the membership successfully argued to get extensions for 6 months or for a […]

  • AALA – American Labeling Automotive Act

    QUESTION: We manufacture a product under HTS # 3907.10.0000. I am trying to determine if our materials apply to AALA requirement. I am further trying to educate myself on AALA. I have been directed to the following websites with no luck on the objective. https://www.nhtsa.gov/part-583-american-automobile-labeling-act-reports & the Cargroup.org Can anyone assist with the above? =========== […]

  • Global HTS Classification Disagreement

    QUESTION: I work for a company that is foreign owned. We have manufacturing sites in several countries. The instruments we manufacture have to be “globally” classified with an HTS number. The instruments we manufacture are not “specifically” named in the HTS headings. We arrive at our classification determination based on the function of the instrument. […]

  • How to clear the shipment with two importers with one MOBL?

    QUESTION: Please help to resolve this situation. The foreign shipper sent two importer’s cargo in one container but declared only one importer and one MOBL. Now when it arrived and cleared customs we were notified that shipment belongs to two different people. Can we file a Post Summary correction and how? How can we present […]