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 […]
QUESTION: Is anyone else in the steel industry or trade community having a problem when filling out the exclusion request with the excel cell rounding their entered data? Example- in the cell for minimum thickness, I type 3.68mm but the exclusion request application rounds it to 4mm automatically. This is not what I typed but […]
QUESTION: Cast of Characters • Company DE • Company KR • Company U.S. • Forwarder DE • Forwarder U.S. • Broker U.S. • Pallet A-U.S. • Pallet B-U.S. • Pallet C-KR Scene (Problem) • Company DE exported Pallets A-U.S. and Pallet C-KR, to U.S. (EXW) • Company DE exported Pallet B-U.S. to KR (EXW) Notes […]
QUESTION: Is it compliant under the OFAC sanctions for a U.S. company, to sell a U.S. product to CITGO for delivery to CITGO in the U.S.? %%%%%%%%%%% ANSWER At the moment, the US has exempted Citgo from its sanctions until July 27. Still, I would recommend flagging as a high-risk customer already now, as these […]
QUESTION: Who does the BAA compliance analysis at your company? I feel like it should be procurement or supply chain. I’m a trade compliance manager and I’m being asked to do it. I feel like it shouldn’t be me. Am I wrong? ********************* Answers: From a procurement standpoint there really is not much for either […]
QUESTION: Does an importer need to apply for a ruling to see if their products qualify under the Nairobi provision, or would it be reasonable to reference an existing ruling for a “like” commodity for justification to use this provision? %%%%%%%%%% ANSWER: To get a better idea of the nuances of the qualification requirements, take […]
QUESTION: We have software that we want to make available for public download from our website in the USA. This would be a trial version of the software that expires after a period of time. If the user wants to continue using the software, they would have to purchase a downloadable software key. To download […]
QUESTION: We are working with a Russian supplier of plastic beads. They will send us free samples. The supplier is requesting that we send them our bank information. There is no sale, no $$ being exchanged. I am told its a “Customs requirement” but not sure how since this is an export from Russia, not […]
QUESTION: We are exporting a product to Korea and supplying the importer with a KORUS Certificate. Korean Customs insists that the classification falls in Chapter 29, but we classified it Chapter 38, clearly based on a Customs Ruling. I had heard in an FTA webinar that you could list two classifications for 1 part, if […]
QUESTION: We are a US based manufacture who will begin exporting to our client in Myanmar Our client, the end user, would like us to use a “third party cosmetic company” to act as the importer of record So the end user client does not have a delay in importing, clearing Myanmar Customs Our client, […]
QUESTION: I reviewed the recent penalty announcement from OFAC and realized I don’t know the answers to some basic questions https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20190131_elf.pdf 1. Is there any de minimus amount of North Korean content that can be in your finished good/component import from a 3rd country? a. Clearly we can not import NK origin goods, nor goods […]
