QUESTION: Researching 301 tariff codes I found something in the tariff that didn’t look like all the others…. 8419.90.8500 UOQ1: X UOQ2: X Parts: 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 […]
QUESTION: Can imports be protected by the Section 301 tariffs when imported as a TIB? ========== Answers: No, TIB imports are not subject to any duty payment, because technically they have not been entered into the commerce of the U.S. BUT, you should be very careful about using TIBs. Their label is literally what they […]
QUESTION: Our company is in a field of oil/gas equipment manufacturing. We constantly deal with sanctioned/embargoed countries. Recently new US sanctions against Russia just came out about business ownership related to Russia, so called “50% rule”. This is in addition to the sanctions already exist against Russian oligarchs, individuals, government officials and business entities. My […]
QUESTION: I was reviewing the list of HS Codes that are part of the Section 301 action and do not always see the connection between the purported reasons for action: 1) China uses joint venture requirements, foreign investment restrictions, and administrative review and licensing processes to force or pressure technology transfers from American companies. 2) […]
QUESTION: Interested in how other members value mass market software for EEI filing. I know EEI is required when the HTS is over $2500 but do you value only the software or the hardware or media that it’s installed on? ===================== ANSWER: Normally the hardware or end media is classified as a finished product and […]
QUESTION: With regard to US Customs having the authority under 19 CFR 12.42 to not release “any class of merchandise that is being, or is likely to be, imported into the United States is being produced, whether by mining, manufacture, or other means, in any foreign locality with the use of convict labor, forced labor, […]
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 […]
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 […]
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 […]
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 […]
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, […]
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 […]
