QUESTION: What is the date used to assess duty rate? · For consumption entry · If an I.T. is applied Warehouse entry withdrawal ========== Answers: This all covered in 19 CFR 141.68 – the date for duty calculation can be elected by the filer for a consumption entry – it can be the date the […]
QUESTION: What are the payment terms generally used by the majority of the membership for international vendors; payment before goods are received, payment after goods are received, etc.? ========== Answers: The best terms to push for are the ROG terms and if you can get additional days it’s a bonus; however, the most common payment […]
QUESTION: I am looking for originating rules for the EU Honduras trade agreement. This is for apparel. Does anyone have a good resource for FTAs not involving the US?,,Thank you! ========== Answers: Most North and South American FTAs may be found on the OAS website sice.oas.org. Your particular agreement is part of the Central American-EU […]
QUESTION: One of our customers in the United Kingdom sends us their French made unit for repair, the repairs are done in the United States then returned back to the customer in the United Kingdom. We’re paying a lot in duty for the import of these units. What options are available to reduce or eliminate […]
QUESTION: I have a Purchase Order for engineering services with a UK company and have recently learned they have a dual national (UK and Iranian) working on this project. The US technology involved is EAR99. Do I have an EAR or OFAC violation? Or both? ===================== ANSWERS: If the UK citizenship was received subsequent to […]
QUESTION: Ok, if things can’t get more confusing, here we go with Sec 301. Does anyone in the membership know if this will also affect LEDs that are sent to a contract manufacturer in Mexico that uses a Maquiladora? HTS code is 8541.40.2000 We send LEDs from out facility in China to Mexico where they […]
QUESTION: One of the customers of one of our foreign subsidiaries was a match on a IMF list of ineligible vendors. Does this preclude our foreign entity from doing business with this customer or does it just mean that the IMF will not do business with them and others can choose to do business with […]
QUESTION: Does anyone in the membership know when registration will open up for the trade symposium in August 2018? All I have found on CBP’s website was save the date info. Thanks! Answer: They generally announce that registration is open via CSMS about 4-6 weeks prior to the date of the Symposium.
QUESTION: We import lighting fixtures from out contract manufacturers in China. They are shipped to our US distribution warehouse, we pay duties on all shipments. We then sell to a customer in Costa Rica. These products would fall under the China-Costa Rica Free trade agreement. Our customer in Costa Rica is asking for the certificate […]
QUESTION: Does the membership have any insight as to how the recently proposed 25% tariff hike on some Chinese-made goods may affect Maquila operations? At first glance, it does not appear this would have an impact on goods that are Immediately Exported to MX. Nor does it appear that it would have an impact on […]
QUESTION: We make in the U.S. an item that requires an export license to China but not to Japan. We sell the item to a Japanese end-user, who installs the item in their equipment. They receive an order from a customer in China, so they export their equipment to China, satisfying applicable Japanese export license […]
QUESTION: When conducting an on-site visit at an US facility by Foreign Nationals under the STA Exemption, is an AES filing required? If yes, what value should be used? ========== Answers: Please see 15 CFR Part 30.2(d)(3) and 758.1 (b) which indicate intangible transfers are excluded from filing. ========== I assume you’re talking about deemed […]
