QUESTION: “Can any embargoed country National work for a US Company subsidiary overseas?The subsidiary is a US wholly owned/and or joint venture 51/49%”***********Answers:The answer would be no. Due to financial remuneration to the worker overseas from US subsidiary, this is covered under OFAC sanctions for the US subsidiary.**********They can, but if your technology or software […]
QUESTION: Can products be in compliance with the Pennsylvania Steel Products Procurement Act if the steel is sourced from the USA but the final product is manufactured in another country? I don’t believe so because substantial transformation to the finished product will occur in another country so the country of origin will change but would […]
QUESTION: I work for a medical device company and someone is trying to send a dead mouse across to Canada for research and testing. Does anyone know what types of certificates you need or licensing to send something like this? ********** Answers: I just have to say – I LOVE THIS QUESTION! You made […]
QUESTION: We are thinking of moving our Free Trade Agreement process & CTPAT supplier survey solicitation to our internal team in Mexico. They would handle customer requests from both customers in Mexico (currently already handling this) as well as customer requests from US customers. I know this has been done by other companies, but are […]
QUESTION: Does anyone have a copy of slip op 94-100? ========== See attached… http://www.icpainc.org/wp-content/uploads/2014/10/Semperit-Indus.-Products-Inc.-v.-US-855-F.-Supp.-1292-Court-of-Intl.-Trade-1994.pdf ===========
QUESTION: Is a dual-use mock-up/model treated as hardware or is it treated as technical data? Would the ECCN/USML classification of the mock-up be classified the same as the operable unit? ========== Answers: Not enough information provided to give an accurate evaluation. However, an article can have more than one ECCN. A good example of […]
Hello ICPA, See the link below courtesy of an ICPA member who had the listing of affected HTS codes translated from .pdf to excel. http://www.icpainc.org/wp-content/uploads/2014/10/Section-301-Proposed-HTS-and-Descriptions-8-Digit.xlsx
QUESTION: Is there something equivalent to a Long Term Supplier Declaration but for the USA? I understand the Long Term Supplier Declaration applies to EU goods. This document is great because it list the origin and any relevant FTA’s. Currently for the USA, we only receive an email from the supplier and not a document […]
QUESTION: Does any agency, such as TSCA, still require an actual form to be completed and filed during entry? I hear DOT does, but I thought that was the only one. ================ ANSWERS: Many agencies have their own forms to be filed out at time of import / export I know for a fact that […]
QUESTION: We have at least one customer who’s claiming that first Russian and now Brazilian Customs is asking for the name and address of pass-through suppliers (i.e., our original supplier). Giving the customer our supplier’s information really isn’t what we would like to do, obviously. What do others do? And is there really a legal […]
QUESTION: For work directly under contract to the US Government, we are permitted to use a Government Duty-Free Certificate (9808.00.3000). Does anyone know if this duty-free provision will apply to the newly imposed tariffs on steel and aluminum? ********** Answers: Your certificate is NOT affected by change in tariff. You will continue to get the […]
QUESTION: Are GRIs global and the same in every country? I assume AUSRIs are specific to the US. If so, when classifying products at a global level, lets say for China, Brazil and Kenya, would you not even look to the AUSRI for guidance when classifying? Also, would AUSRI 1(c) related to classification of “parts” […]
