Miscellaneous

MISCELLANEOUS

  • CHASSIS DESTRUCTION UNDER EPA IMPORT

    QUESTION: We imported two vehicle chassis using an EPA exemption and temporary import bond. The chassis were to be altered and then exported to our customer. The sale fell through and we are out of extensions for the exemption and bond. We have exhausted all possible options to return them or sell them without any […]

  • RELATED PARTY INDICATOR

    QUESTION: Our company acts as the non-resident U.S. importer of record for shipments ordered by our customers from our offshore manufacturing plant. We show the sales price to our customer as the transaction value on the 7501. Our transactions reflect related party on the 7501 because the shipper and IOR are related parties. Noting that […]

  • RISK ASSESSMENT FOR PENALTIES

    QUESTION: I am currently working on a justification project where I have been asked the value and number of penalties assessed by CBP and CBSA over the past few years. I have been able to find CBSA data but have not found CBP data.  Does anyone know where I can access this information?  Any information […]

  • RUSSIAN SANCTIONS DILIGENCE

    QUESTION: According to EU/US Russian sanctions regulations EU/US persons need to check carefully to see if an entity with which they are dealing is 50%, or more, owned (and controlled/EU) by a SDN/DP. Does anyone in the membership know if this due diligence requirement extends beyond direct customers (distributors, OEMs, resellers etc) to include indirect […]

  • RUSSIA IMPORT REGULATIONS

    QUESTION: I recently read that all import shipments into Russia must contain the original equipment manufacturers (OEM) name and address per line item. Is this true?  Has anyone experienced this while importing into Russia?  What about purchasing from distributors and resellers, they are not going to tell their customer/importer where they purchase the goods,  so […]

  • IMPORTING DUAL USE GOODS FROM INTL WATERS

    QUESTION: If I would take ‘Dual-Use’ goods classified in the EU under 6A001.a.2 ( a hydrophone)  from France and load it on the French (flagged and owned) Vessel,  sail into international waters and do some ‘sea-trials’ where at all times the ‘item’ is attached to the vessel, and take it back into the vessel and […]

  • FOREIGN PARTNER SHIPPING TO IRAN

    QUESTION: My US company has a 50% ownership of a French company.  This French company has a manufacturing plant in the UAE, which exports to Iran.  Are there any legal concerns for us for having part ownership in this foreign company?  The product is EAR 99 and has no US components.  What about if the […]

  • US CITIZEN WORKING FOR NON-US ENTITY

    QUESTION: A US Citizen is accepting a position in Asia for a non-US entity. This non-US entity owns us, a US entity. The Citizen will be President of the company. Can the membership assist in what, if any, due diligence must be done in regards to US restrictions on Denied Party Screening / Restricted Trade […]

  • USPPI SCENARIO

    QUESTION: I am doing research for I came across an unusual event in my supply chain.  There is some information on the membership site, but not exactly my situation.  So I have 2 questions. My parent company is located in Germany,  They import into the USA under their own Customs assigned number and naturally the […]

  • DOCUMENTING TECH TRANSFERS

    QUESTION: So I know that EEI filing for technology (intangible/electronic transmission) isn’t required , the technology in question involves encryption (ECCN 5E002) and is under license exception (ENC); the export is to another foreign subsidiary.   My question is :   How’s such transaction documented? Are there best practices for such transactions? Any info or […]

  • VAT NUMBER REQUIRED FOR O/BL TO EU

    QUESTION: We are shipping material from Asia directly to our EU subsidiaries and sometimes directly to their customers.   Many of the contracted ocean carriers insist on getting the VAT numbers of the parties on the bill of lading (consignee and notify parties).   This VAT number does not show up on the bill of […]

  • M&A IMPORT SCENARIO

    QUESTION: I am seeking for some guidance and or sharing experiences best practices on oversea shipments customs clearance during M & A as result of name change particularly Latin America and Asia Pacific countries ? E.g. the BOLs and commercial invoices would read ABC Company but when it gets to destination ABC became XYZ – […]