QUESTION: We are a US based importer/exporter of manufactured goods. We are working on a screening process for banks that our customers use to send money from/that we send money to. We receive a list of bank transactions that include bank names & addresses. However, many times only the main branch or corporate address for […]
QUESTION: We are a U.S. based company, our goods are manufactured in the U.S. with ECCN 3B992. We perform intercompany sales to our German affiliated company and they classify the same items as 3B002. Should our German counterpart follow the U.S. classification which in turn would be NOCLASS or can they override the classification since […]
QUESTION: Hello, our company is not ITAR registered and we are in the software business, we also provide consulting services regarding our products worldwide. Sometimes consulting customers can be defense companies. My question is about the definition of “Defense Services” under ITAR, it says “furnishing of assistance to foreign persons”, but does not say by […]
QUESTION: We sent a defense article controlled by Category XI(b) (SME) under a DSP-5 license to a government end-user several years ago. This item (in its entirety) is manufactured by my company in the United States. They let us know that they are finished with the defense article, as it’s reached the end of its […]
QUESTION: I have been seeing questions regarding a USA employee working for a USA employer and asking if they could perform “customs business” for subsidiaries, …etc. Also read regarding a USA employee working for that USA employer that is a subsidiary of a holding company in a foreign country, and that holding company is also […]
QUESTION: Can anyone direct me to more information that explains the concept of “principle use provisions”. Can you share electronic versions of the following? • T.D. 89-80, 54 Fed. Reg. 35127 (8/23/89) • E.M. Chemicals v USA 20 C.I.T. 382, 923, F. Supp. 202 (1996 Ct Intl Trade) • Group Italglass U.S.A., Inc. v. United […]
QUESTION: Does anyone have any feedback in the membership as it relates to non-US employees managing imports into the U.S.? Is there concern over allowing them to access the data that will be transmitted to US customs? Is there a section in the regulations that addresses this matter? ************* Answers: It’s perfectly fine. There is […]
QUESTION: Regarding tariffs and duties: Lithium batteries and cells imported from China from our a wholly owned subsidiary, are produced, in part, using materials that are provided from our plant in the USA. The materials that are shipped from our USA plant to China are made and sourced in the USA. I don’t have an […]
QUESTION: I am looking for data regarding how companies structure their organization for personnel that are responsible for HS classification determination. I am particularly interested in large companies classifying chemical or other commodities that require specialized technical skills (for example: a chemist) for classification. Is it centralized under one department? Is it centralized under one […]
QUESTION: Has anyone from the membership successfully argued and eliminated the duty/fee liability where goods were seized because of an OGA requirement not met and not entered into U.S. commerce as a result? If so, what regulation/guidance was relied on in presenting to CBP. Thank you for your time in advance! **************** Answers: Not sure […]
QUESTION: What is the benefit to have a CBP national account manager? What size of company is good to have one. We are in the CTPAT program, we have a custom assigned agent look after our CTPAT, is this person also our national account manager. What are some disadvantages to have CBP national account manager? […]
QUESTION: We are a pharmaceutical company recently expanded. We hope to implement a single global standard on determining country of origin. We do not take advantage of FTA’s as they do not financially benefit us. Any thoughts on the possibility of implementing one global process applicable in more than 50 countries? Would it be advisable […]
