QUESTION: I would like to ask other chemical manufacturers, or related industries, how they manage program ownership of regulations, such as drug precursors, chemical weapons, or FDA products. Does the product regulatory team own the programs and set the SOP for each group, i.e. global trade, domestic, plants? Or is it a shared ownership between […]
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 […]
QUESTION: I would like to know if anyone else in the membership has been asked to be the Importer and Exporter of record for China, Brazil, India and Japan? We aren’t too concerned with Japan but would like to know if anyone else has any pointers or tips for doing so with China, Brazil […]
QUESTION: Can a Customs Brokerage (ABC Brokers) lease an unlicensed employee from a non-brokerage company (XYZ Company) to act as an entry writer under the supervision of a licensed Customs Broker (the licensed Broker works for XYZ)? Both ABC and XYZ are related companies. The unlicensed employee would not be paid by ABC Brokerage, but […]
QUESTION: Would anyone like to share an SOP/standard for import self audit? I would also like to create one for our foreign affiliate (EU). We are looking to audit 10-15% of our imports. How frequently would you recommend for a small importer of raw materials (no FTZ). ************ Answers: I suggest that you set up […]
QUESTION: Has anyone in the membership prepared a questionnaire to send to their suppliers in China, or elsewhere in response to the Countering America’s Adversaries through Sanctions Act (H.R. 3364)? Any recommendations on how best to approach vendors overseas? ************ Answers: This seems to be a 2 step approach including HR and Supply Chain. […]
QUESTION: My company has routed exports and I am trying to set up a procedure on how to manage Letters of Authorization and End User Certificates , I am looking for advise from the members on how to keep track of the letters of authorization and EUC, so here are the questions: How do you […]
QUESTION: Is anyone working in the driverless car sphere? It would seem to me that both the technology and hardware would be somewhat highly controlled. Yet I don’t seem to be able to find a place on the CCL for them. Any thoughts on this subject would be appreciated. ================== ADDITIONAL ANSWER: […]
QUESTION: We are shipping a laptop to Mexico. Our broker in MX request that we provide an MSDS to cover the Lithium Battery in the laptop. With regard to lithium batteries and this particular example, is the MSDS required in this instance or only when you have bulk shipments of lithium batteries? If an […]
QUESTION: Does anyone know if there is a requirement that Importer of Record (IOR), using approved alternate method of storage under CFR19 §163.5, keep digital records only on Servers located in the US? I do not recall this restriction (other than for Customs Brokers). I did a quick search of Cross Rulings and Federal Register, but […]
QUESTION: Our global customers who are distributors return purchased product to our US facility for warranty consideration. When we ship replacement product, the distributor in the foreign country has to import the product and incur duties again, even if the product is being replaced free-of-charge under warranty. We would like to give the foreign customer […]
QUESTION: We have an issue where the laptop of our sales rep in MX does not work. They have been using tablets and smaller options as a stopgap but that is not doing the trick. Because of sensitive company specific sales and marketing information and company sales call software programs need to be uploaded we […]
