Miscellaneous

MISCELLANEOUS

  • 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 – […]

  • CENSUS NOTIFICATION LETTER

    QUESTION: Does anyone have experience in requesting a ‘Census Notification letter’ to customs?   Not sure what the letter is called, but it is to request eliminating census errors for certain recurring value/qty errors in ACE. This ‘Census Notification letter’ gets submitted to customs to notify of the recurring errors so they can investigate your […]

  • REUSABLE CONTAINERS

    QUESTION: We receive and send reusable plastic and cardboard containers / crates to and from Mexico and Canada. And to and from Japan.   Is there a way, other than using 9803.00.50 (for the plastic, obviously not the cardboard) and all the rigmarole (i.e., tracking individual containers and bonds) to avoid paying duties on this […]

  • GLOBAL MANUFACTURING HUBS

    QUESTION: In general terms, our company is looking to identify potential manufacturing sites overseas and is reviewing landed cost (including duties, Free Trade, etc.) and Customs/export shipping ease.   One question that was asked was, in generic terms, what countries around the world have efficient global export hubs with strong import/export infrastructure and Free Trade […]

  • BAG AND TMP

    QUESTION: Is the use of the exceptions BAG and TMP only required for items requiring an export license? I have seen examples of phones and computers being listed on these forms for customs purposes when an export license is not required. ========== Well the answer is “yes”.  You do not use a BIS LICENSE EXCEPTION […]

  • ZIKA DISINFECTED PROCESS FOR CHINA

    QUESTION: China’s General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) implemented a policy in early 2016 under which China-bound cargo shipments originating in Zika infested  countries (e.g., Thailand, USA) must be “disinfected” to kill mosquitoes or larvae present in the cargo.  AQSIQ then regionalized Zika Virus disinfection requirements for US to vessels originating from […]

  • LICENSED BROKER VISITING CUBA

    QUESTION: May a licensed US Customs broker go to Cuba and retain their license upon return? ========== Answers:   Are you traveling, or doing a temporary work assignment? Your personal license is not forfeited at any time due to location to my knowledge.  Stay in communication with your licensing CBP office and keep them updated […]