Miscellaneous

MISCELLANEOUS

  • Liability in providing EEI to foreign parties

    QUESTION: We have a customer that is having us drop ship items to foreign entities via a small parcel courier. They are insisting that we put a paper copy of the EEI filing in the box when we ship. I have pointed out that this is illegal per the Census Regulations, but they still insist. […]

  • CUSECO and CUSICO

    QUESTION: Has anyone taken the CUSECO or CUSICO. How is the difficulty compared to the Customs broker License Exam. Would you have sample questions to share for CUSECO or CUSICO. If not would you know where I can find these questions. ========== Answers: I took the CUSECO exam and passed on the first try. It […]

  • Rules of Origin

    QUESTION: Does anyone know, or have insight as to, what will happen to 19 CFR Part 102 “Rules of Origin” (commonly known as the NAFTA Marking Rules) upon implementation of the USMCA ? =================== ANSWERS: Before there can be “implementation” of USMCA, it first needs to pass as a law, hardly a certainty to start […]

  • C’NEE CHANGING HTS

    QUESTION: We produce, classify and sell a finished part to an International distributor. This distributor in turn resells our part (without any additional processing, changes, alternations, etc), to their customer. When the distributor resells our part, they are changing the classification to significantly lower the duty rate without discussing the change with us. We have […]

  • WORLD BANK VS BIS SCREENING LISTS

    QUESTION: We received a Double Red Flag alert from our Restricted Party screening provider for a customer on the World Bank of Ineligible Firms I understand firms and individuals listed are sanctioned under the Bank’s fraud and corruption policy. While the World Bank of Ineligible Firms listing is not part of BIS Listing of Parties […]

  • CHANGE DECLARATION OF OWNER

    QUESTION: I know that form 3347 is only valid if it’s presented within 90 days of the date of entry. If the entry has been more than 90 days, is there a different form or other option to change the declaration of an owner? ========== Answers: Can your customs broker cancel the entry and resubmit […]

  • CONSOLIDATED SCREENING LIST

    QUESTION: I was looking for the government’s Consolidated Screening List, but I’m not finding it where it once was. Was it moved? Is it unavailable during the shutdown? *************** Answers: Is it unavailable during the shutdown George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 […]

  • STOCK TRANSFER VALUATION

    QUESTION: Wondering who in the industry also uses stock transport orders (STO) and how do you deal with payment? We issue a PO to transport goods from one foreign plant(which we own) to our US plant and there is no record of a financial payment on this movement. How do I conduct a 3 or […]

  • US Co. JV in Saudi Arabia

    QUESTION: I work for a US Company and we are negotiating our first JV in Saudi Arabia. I’ve gotten management to agree to invite me, Trade Compliance Manager, into the room for the discussions. So, what do I need to know? Big picture stuff I need to keep in mind? Iran. Anti-boycott. But what else? […]

  • USING STA EXCEPTION

    QUESTION: We have a component manufactured in the USA that falls under ECCN: 0A987.g and requires a Commerce Dept license (Reason for Control FC1) This item is shipped from USA to Canada to be incorporated into a larger assembly. During the government shutdown, is utilizing the STA Exception a possibility? Or is it disallowed because […]

  • Revised CF5106

    QUESTION: I was recently made aware of the revised form set to be implemented in early 2019, depending on when the government is open for business again. Section 3 will present challenges for my group companies. I’d love to hear how other companies plan to address internally. ***************** Answers: Not the best solution, but I […]

  • SoCAL USE OF TIB FOR SEC. 232 AVOIDANCE

    QUESTION: I’m looking for input from the SoCal membership. Operations in LA & SD claim that “everyone” is using TIBs to import material into the US for processing and re-export to Mexico, avoiding payment of 232 tariffs. I find this hard to believe understanding what I do about TIBs. Any insight on this topic from […]