Miscellaneous

MISCELLANEOUS

  • New Global Trade Director

    QUESTION: We are a Fortune 500 Company headquartered in the U.S.  Our current Director of Global Trade Compliance is moving into a different role within the company, and we have a new Director of Global Trade Compliance who will be located in Belgium and is not a U.S. citizen.  Are there any concerns about having […]

  • Question on 19 CFR 192.1 and 192.2

    QUESTION: Would a bus, with the engine removed, be considered a self-propelled vehicle as defined in 19 CFR 192.1 and subject to the requirements of 19 CFR 192.2 upon export to Canada? ================= ANSWER: If the engine has been removed, I would think that the bus does not fit into the definition in 192.1 and […]

  • SEC 301 TIMELINES

    QUESTION: Would the membership advise where we are currently in the Sec 301 additional tariffs announced by the USTR?  As I understand, List 1 was effective 07/06/18 and duty rates are 25%.  List 2 is currently in the comment stage and duty rates are 25%.  The final list, made public by the USTR last week, […]

  • AUSTRALIAN STINK BUG COMPLIANCE

    QUESTION: I am concerned the cost for fumigation and delays in importing could hurt our customers. I have read DAWR requirement for Brown marmorated stink bug (BMSB). The fumigation will be required for most products from Sept 1 2018 to April 30th of 2019. Any ideas for dealing with this costly process ? A long […]

  • PARTIES TO A TRANSACTION

    QUESTION: The following definitions are somewhat circular.  Can someone please provide some examples of each type to better clarify the differences. Purchaser. The person abroad who has entered into a transaction to purchase an item for delivery to the ultimate consignee. In most cases, the purchaser is not a bank, forwarding agent, or intermediary. The […]

  • CUSTOMS IMPORT CHARGES

    QUESTION: Can anyone provide a list of all possible charges when you are importing into the United States? Anything that would add to your cost of importing. I know that there are some customs charges that I may not be aware of ********** Answers: From the broker: Too many to list them all but here […]

  • Hiring Foreigners

    QUESTION: My company recently hired individuals to work in R&D.  The individuals come from China and Russia.   The commodity they will work on has an ECCN of 3A981, 3D980, and 3E980. Is there an export control concern here with these individuals working here? Do we need to segregate their duties so they are not allowed […]

  • Protests and Refunds from HM Revenue (UK/GB)

    QUESTION: Does anyone have any experience trying to collect refunds from HMRC? Scenario:The UK division has historically been importing an item as a “part of” the finished good. I feel the articles in question are specifically excluded from the “parts of’ provision, and are classified under their own subheading. The duty difference would net the […]

  • Reference sheet: U.S. Embargos and Sanctions Programs

    QUESTION: If anyone in the membership has a reference sheet that summarizes current U.S. Embargos and Sanctions Programs, can you please provide? It would be great if it is broken out by the type of US entity (US person, foreign owned entity, etc…), type of transaction, sanctioned country and type of restricted party. ========== Answer: […]

  • HTS MISTAKE IN SEC 301 LIST

    Of electromechanical tools for working in the hand with self-contained electric motor Now I have seen descriptions like that in other parts of the tariff- but 8419 has nothing to do with tools 8419 Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the […]

  • EEI filing for small shipments exported via courier, over $2500

    QUESTION: Most of our exports are routed and as such the EEI filing is processed  by the FPPI’s  designated freight forwarder. How does the group handle the EEI filing for routed transactions when exporting small shipments that the FPPI requests be sent via a freight forwarder? Some freight forwarders do not offer an EEI filing for […]

  • ZTE SANCTIONS

    QUESTION: On July 13th Department of Commerce and BIS issued a notice that the Denial Order for Zhongxing Telecommunications Equipment Corporation, of Shenzhen, China (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (“ZTE Kangxun”) (collectively, “ZTE”) had been lifted and both parties were removed from the denied parties list. A signed Final […]