QUESTION: We have a US customer, that we make a sale to domestically. The product comes from overseas and we ship it directly to our customer (from our manufacturer), they are the importer of record (the US customer). From my standpoint, this is a domestic transaction. We have been doing all the paperwork, indicating […]
QUESTION: With regards to MID Code construction, CBP requires “the ISO code for the actual country of origin of the goods” as the first two characters. However, our vendor invoices note a different country (e.g. CoO CN and Commercial Invoice address Taipai Taiwan) such that our broker is using TW as the first two characters. […]
QUESTION: Is using the Consolidated Screening List on export.gov sufficient for showing due diligence for all of the sanctions and denied parties checks? Are there any sanctions or other lists that should be screened that are not on the CSL? ********* Answers: If you are a small entity with no overseas business it MAY be […]
QUESTION: I’ve been asked to “weaponize trade compliance” at my new job. I think that the best way for me to do this is to show how trade compliance can actually make a company more efficient and give it a competitive advantage. Can anyone suggest any resources (white papers, etc) on how best to present […]
QUESTION: We are an importer of record and purchase from a related party overseas. We have received a retroactive price contract from one of our customers. The invoice value we used at time of entry is the pricing we had on file. Now we have the new pricing on file and it is retroactive. We […]
QUESTION: We currently have contract manufacturer’s in China who prepare our FG. We send them US materials and they combine with Chinese components. The China CM’s manufacturing process does not result in a substantial transformation of the US material and the COO would be US. Our product’s HTS is included in the initial list of […]
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 […]
