Miscellaneous

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?  […]

QUESTION: We are reviewing and updating our hand-carry procedures. A business traveler carries a laptop.    If the software and technology loaded onto the laptop is taken overseas and meets the 734.18(a)(5) criteria: (5) Sending, taking, or storing “technology” or “software” that is: (i) Unclassified; (ii) Secured using ‘end-to-end encryption;’ (iii) Secured using cryptographic modules (hardware or “software”) compliant with […]

QUESTION: For those responsible for classifying products which are highly customizable, such as motor assemblies, how are you currently interpreting the release provisions under paragraph (b), and more specifically, those related to commercial “equivalent” for commodities “in production”? For example: A company offers a commercial series of production motors, which includes a clearly defined spectrum […]

QUESTION: I’m a Trade Compliance Manager and I’ve been asked to summarize the Buy America and Buy American Acts for my company. (I’m pretty sure these are more for Procurement, Supply Chain, and Contracts people, but I am not in a position to decline.)Does anyone in the membership have high-level summaries of these?  Any other […]