Miscellaneous

MISCELLANEOUS

  • Ultimate Consignee for EEI

    QUESTION: I think I am overthinking this, I know the Ultimate Consignee definition – (3)Ultimate consignee. The ultimate consignee is the person, party, or designee that is located abroad and actually receives the export shipment. If the shipment is sent from the US Company A to Foreign Company B in Germany and Company B in […]

  • HS 84661001 AND SEC 301

    QUESTION: Has anyone heard anything further about applicability with regard to HTS 84661001? The description listed in the Notice of Determination says: Tool holders and self-opening dieheads for use solely or principally with machines of headings 8456 to 8465, nesoi However, what if your item doesn’t fall under parts and accessories suitable for use solely […]

  • CN MADE MEDICAL DEVICE IMPORTS

    QUESTION: Our medical devices are designed by us, a US company, and manufactured in China. The proposed tariff would add 25% additional cost to the majority of one of our product lines. This proposed tariff will put a significant financial strain on this product offering. Thoughts from other members impacted by this tariff? (are others […]

  • CUSTOMER REQUESTED HTS

    QUESTION: We have started receiving customer requests, not unexpectedly, to not use particular HTS classifications on our customs documentation. Does anyone have any language they use to respond to these requests? ========= Answers: My first response would be to state in no uncertain terms that using an incorrect HTS in order to avoid the payment […]

  • End User Cert criteria

    QUESTION: I’ve been asked to clarify our vague corporate policy on end user certs. I’m going to suggest this as a baseline. Thoughts? Every international transaction (if it crosses a border). Every domestic transaction involving a distributor or any other transaction where you know (or reasonably think) that the shipment might be destined internationally. Also, […]

  • Unverified List

    QUESTION: My company has a customer that recently appeared on the Unverified List.  The customer was selling the products they purchased to a third party (Programs did not request an end-use/user certification for previous sales).  Now the third party wants to do business directly with us, and the customer (on the Unverified List) said that […]

  • AUTH AGENT UNDER 30.3(e)

    QUESTION: I’ve seen a lot of emails regarding Routed Export Transactions the responsibilities related to the EEI filing.  It’s piqued my interest. It’s clear that 30.3(e) provides instructions for who files the EEI.  The FPPI authorizes an agent or the USPPI to file, it does not mandate them. The questions I never thought of until […]

  • CONSOLIDATED CONTAINER SHIPMENTS

    QUESTION: Vendor in Italy contracts with a warehouse in the US to “warehouse” our cargo until we wish to purchase it. We assumed they would clearing through Customs and it would be a domestic sale to us Instead, we are told that our cargo is in a container with another of their clients cargo, and […]

  • After Acquisition Integration Plan

    QUESTION: Does anyone have an “after integration” plan for  customs compliance. We recently acquired another company, we already completed the due diligence checklist and now I am looking to see if anyone has an “after acquisition” playbook they wouldn’t mind sharing? ========== Answers: Don’t know what your initial due diligence process is like so not […]

  • 818 Tariff

    QUESTION: Is there an exclusion request and objections similar to the Steel and Aluminum we can apply for, for items on the 818 tariff?  (specifically for motors) ========== Answers: Not yet, but it has been promised to be set up ========== There will be, as mentioned in the final determination, but it’s not published yet. […]

  • Cargo being sent to a Duty Free Ship

    QUESTION: Does a  Duty Free Shop have to receive cargo from a bonded warehouse regardless of types of products or is this limited to only liquor/tobacco/firearms? ================= ANSWER: A “duty free shop” or “duty free stores” are a “Class 9” bonded warehouse. Reference 19 CFR §§19.35 – 19.39. The types of duty free merchandise eligible […]

  • Question on selling to Syria

    QUESTION: If we find out one of our foreign distributors has been selling products to Syria, even if it is not our products, what obligations do we have now?  They have been advised they cannot sell our products to Syria, but do we have to stop selling to them if they are only selling other […]