QUESTION: Can foreign producers reimburse Section 301 duty payments made by importers? ========== Answers: I believe this would be considered a rebate and advise against it. ========== Yes. This is not like anti dumping or CVD. ========== Yes, it is legal for suppliers to reimburse importers for the Section 301 duties. We have had a […]
QUESTION: Our sister site in the UK needs to obtain reexport authorization for an ITAR controlled item. Our site in the U.S. is not involved in this transaction in any way. I believe it is best for the GC requesting the authorization to be sent directly from the UK site to DoS; however, I want […]
QUESTION: We are contemplating setting up a Drop Shipment scenario between US, CN and SK. SK company would send PO to US company. US company would send PO to CN related party. CN company would ship to SK company. We want the final invoice that the SK company and SK Customs sees to be the […]
QUESTION: When the Federal Register says ” Prohibition on the export to Russia of any goods or technology on that part of the control list established under Section 2404(c)(1) of the Appendix to Title 50″ Is that referring to items controlled for National Security (NS) reasons? We’re trying to figure out exactly what these new […]
QUESTION: Does anyone have a rules of origin , 19 cfr part 102, presentation they are willing to share? ========== Answer: Section 102 rules of origin only apply to certain trade agreements (NAFTA) an apparel. Section 102 has limited applicability … The preamble provides … 102.0 Scope. With the exception of §§102.21 through 102.25, this part […]
QUESTION: Who pays for demurrage at destination airport for Incoterm CIP Destination Airport ? ================ ANSWERS: Per CIP Incoterms, that is specified in the contract of carriage. If the CoC shows destination is airport or ocean port, then demurrage would be up to the buyer. Please, see attached Reference chart for more details. http://www.icpainc.org/wp-content/uploads/2014/10/Incoterms-Reference-Chart.pdf ======================= […]
QUESTION: I hope some experts can help answer the below scenarios on MID construction. Thank you in advance. Here are the three scenarios that would be good to confirm: On CF7501 Instruction for MID, it is noted that ‘for the purposes of this code, the manufacturer should be construed to refer to the invoicing party’. […]
QUESTION: With Brexit looming in March 2019 how are companies preparing for the changes? What will the impact be on the operational side of the transaction? Currently as part of the EU there are no borders and therefore no customs clearance for movement of goods from mainland Europe to UK. I’d be interested to understand […]
QUESTION: The semi-annual reporting requirement under 740.17(e)(1) for certain encryption items described in 740.17(b)(2) and (b)(3)(iii) is clear. But is there actually a fine or penalty for failure to report? What is the compliance risk of non-reporting? Do BIS and NSC actually review the reported data? Management is looking for justification for this activity. I […]
QUESTION: How far in advance does CBP allow the entry to be made prior to the port arrival on vessel shipments? Can it be further out than 5 days prior? How significant is the port arrival date you provide on the entry? Does it matter if the ETA you were originally given is 1 or […]
QUESTION: We have a vendor that would put our shipment into a bonded warehouse under their bond. We would like to be the importer of record for withdrawing from the warehouse. Can this be done? Does it have to be the same broker doing both? =========== Answer: Yes it can be done, just contact your […]
QUESTION: I am looking for some guidance and possibly some government interpretation of classification of optionally piloted aircraft from folks that export these types of aircraft. On the EAR the aircraft is 9A991. If it is modified to be optionally piloted, does it stay 9A991 or change depending on the how the export is effected? […]
