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 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 […]
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 […]
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 […]
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 […]
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 […]
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. […]
