Miscellaneous

QUESTION: Our parent company is requiring us to complete a High Risk Profile questionnaire on all new Business Partners (who sell our product) and customers, as well as an updated questionnaire after 2 years. This is in addition to a RPLs screening at the time of being setup in our ERP system, as well as […]

QUESTION: Does anyone know if it is acceptable to show 2 currencies (USD and BRL) for different line items on the same commercial invoice? The Brazilian importer is asking for that and with all of the horror stories of delayed shipments I wasn’t sure if this would cause any delays or confusion upon import. We don’t […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]

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 […]