Miscellaneous

MISCELLANEOUS

  • FOREIGN NATIONAL VISITOR CHECK-IN

    QUESTION: Our company is considering to buy a visitor registration system.  A visitor would arrive at the main lobby, sign in, show ID, get a picture taken, name tag is printed out and given to the visitor.   From a trade compliance standpoint, particularly exports and deemed exports, is there any functionality we should ask […]

  • CALIF PROP 65 LABELING

    QUESTION: Do the current California Prop65 Warning Label requirements indicate if the warning label must be attached to the item itself if it is sold online and there are warning on the website product page?   Will they be required on the item itself for online sales after August of 2018? Answers:   Proposition 65 requires […]

  • COURT CASE 77-7-01188

    QUESTION: Can anyone share this case ? Pharmacia Fine Chemicals, Inc v US Court case 77-7-01188 ************* Answers: I’m guessing it’s a 1977 case, but all I can find are these: https://scholar.google.com/scholar_case?case=8429272546483017003&q=%22Pharmacia+Fine+Chemicals%22&hl=en&as_sdt=3,30 https://scholar.google.com/scholar_case?case=11772847799044195637&q=%22Pharmacia+Fine+Chemicals%22&hl=en&as_sdt=3,30 ************ http://www.icpainc.org/wp-content/uploads/2014/10/ICPA-answers.docx

  • LICENSED ITEM IMPORTED FOR REPAIRS

    QUESTION: An item shipped from the U.S. under export license (State) then returned for repairs. What are the requirements to re-import ? Must this be imported under a TIB if duty free ? What are the requirements to re-export ? ========== Answers: If duty free I would not import as a TIB, not worth the […]

  • FORCED LABOR TEMPLATE

    QUESTION: Can anyone in the group share a blank inspection report or survey used to verify if the suppliers they are dealing with are involved in forced/child labor? We are not quite sure how to approach this topic but want to develop a process. ========== Answer: We start with requiring suppliers to sign our corporate […]

  • EXPORTING CERTIFICATES WITH SHIPMENTS

    QUESTION: My company sends a variety of different certs with our shipments. The main types are calibration certificates and certificates of compliance. These are often entered as lines on the Purchase Order from the customers and therefore are listed on the corresponding Sales Orders and commercial documents. How do other companies handle valuation and classification […]

  • JOINT VENTURE COMPLIANCE MANAGEMENT

    QUESTION: Company A (40% ownership) is part of a joint venture in the US with Company B (60% ownership). Company A has a trade compliance manager, however, Company B does not. Each operate under different company names and IOR numbers.  My questions are as follows:   Are there any legal issues with the trade compliance […]

  • DPL SCREENING PROCESS

    QUESTION: I am interested to know what best practice is regarding DPL screenings.   1) How often should we conduct the screening? 2) Some members of my procurement team advise that if we screen every transaction at time of shipment it slows the shipment down.  If this is an automated process that takes merely seconds […]

  • ETHANOL WIPES

    QUESTION: Our company imported 100% ethanol wipes which are used for cleaning tools and electronics , the HTS# we used is 6307.10.2030 (wipes of man-made fibers)  since they’re wipes and not alcohol. Our Safety Engineer seems to think (based on info from an outside source)  that we should’ve notified TTB (Alcohol , Tobacco Tax, and […]

  • PITCHING TRADE MGMT SOFTWARE

    QUESTION: I am in the process of building a business case/proposal for implementing a Global Trade Management Software for my company.   In my organization, we have a 2 person group (Trade Compliance Manager & Director of Transportation) overseeing all trade compliance functions within the U.S. and it has been noted from our foreign locations […]

  • PROVING PAYMENT IS NOT AN ASSIST

    QUESTION: Our company selects and nominates material suppliers in Asia from whom our foreign manufacturers buy those materials. Sometimes, factory will not meet the Minimum material order requirements. Supplier will impose a surcharge for it to our unrelated manufacturer/factory. Factory will charge us back for it. ( it is not in the contract).   I […]

  • EFFECTIVE IMPORT EXPORT PROGRAM

    QUESTION: Is there a standard set of elements that comprise an “effective” import and export trade compliance program?   The Federal Sentencing Guidelines spell out elements for an effective compliance program, however, trade compliance seems to have many special areas and regulatory bodies.   Any thoughts would be appreciated. ========== Answers: You need to analyze […]