Miscellaneous

MISCELLANEOUS

  • SUCCESSFUL EXCLUSION REQUEST PROCESS

    QUESTION: We are starting to receive exclusion requests from customers that have been approved by BIS.  We have submitted all required information to the email traderemedy@cbp.dhs.gov as instructed in CSMS #18-000378. My question is what is the time line for CBP to enter these exclusions in their system so we can begin our post summary […]

  • RUSSIAN SCREENING MATCH

    QUESTION: We have screened a Russian individual thru our screening software and received a ‘Hit” related to CAATSA – Senior Political Figures and Oligarchs in the Russian Federation I am not familiar with CAATSA but upon doing some research it appears this is not a sanction list.  I do not understand the purpose of CAATSA […]

  • SUCCESSFUL EXCLUSION REQUEST PROCESS

    QUESTION: We are starting to receive exclusion requests from customers that have been approved by BIS.  We have submitted all required information to the email traderemedy@cbp.dhs.gov as instructed in CSMS #18-000378. My question is what is the time line for CBP to enter these exclusions in their system so we can begin our post summary […]

  • Miscellaneous Tariff Bill – HTS Codes

    QUESTION: Does anyone have a list of the tariff numbers that will be impacted by the miscellaneous tariff bill 2018? ========== Answers: Attached is the link to the version passed by the Senate. https://www.congress.gov/115/bills/hr4318/BILLS-115hr4318rfs.pdf ========== Here is the full list of MTB HTS codes. http://www.icpainc.org/wp-content/uploads/2014/10/Copy-of-MTB-2018.xlsx ========== Hi, Attached is a spreadsheet showing the HTS, MTB […]

  • CA Prop 65

    QUESTION: Is anyone aware of the CA Prop 65 process? Trying to understand what other companies are doing and if there has been an implementation date? Is everyone using a Safe Harbor Label? ========== Answers: The process is unchanged since Prop 65 went into effect in 1986.  Enforcement is primarily through citizen enforcers, affectionately known […]

  • IMPORTING FOR DESTRUCTION

    QUESTION: Under contractual obligation, we have surplus product that is required to be destroyed in US. Product would need to be moved to US, and the products’ classifications have duty rates as well as additional duties under temporary legislation. We are exploring how to accomplish destruction with minimum financial impact. The below methods have been […]

  • MULTI-COUNTRY PURCHASE SCENARIO

    QUESTION: Facts Company A in US purchases goods from Company B in US Goods are manufactured at Company B in FR Once manufactured, goods need to end up at Company C in DE to incorporate into prototypes for Company A in US What we want to do is ship directly from Company B in FR […]

  • DSP-5 denial

    QUESTION: Has anyone from the membership gained licensing approval after a DSP-5 denial where the the Department of State determined that foreign consignee/end-user was an unreliable recipient of U.S.-orig in defense articles, defense services and technical data? If so, what actions were taken to rebut/improve the stance to get the approval in the follow-up license […]

  • Corporate Compliance Activities question

    QUESTION: My employer has a 50/50 JV with another company. Under 19 CFR §111.1 there is an exception to the “customs business” requirements called “corporate compliance activities” which allows related business entities to perform import activities to each other. The exception has ownership threshold of more than a 50 percent. In Ruling HQ 116220 CBP […]

  • Section 301, Assists and Transfer Pricing

    QUESTION: We ship US component parts to a related foreign supplier in China who in turn incorporates them into a finished product and exports back to us. I see an opportunity to lower our customs value and therefore avoid Section 301 duties but not sure how we claim the assist value on the item if […]

  • MTB Clarification

    QUESTION: It is my understanding that with the MTB program you are only permitted to get relief with product you petitioned for. Yet on the Excel version of the petitioners and the product there is a column that says ” Relief sought available to any importer” .  There are many products marked yes. Is this […]

  • Increase in Census requests?

    QUESTION: Has anyone seen an increase in the Census requests for pricing information?   We have been participating for years, 1 request a month like clockwork,  with no deadline, and 4 or 5 parts. I am now receiving 2 or 3 a week with 48 hour deadlines. I don’t know if it’s  a new Census […]