• RECORD RETENTION TIME PERIOD

    Question: I’m responsible for record retention at my company (we’re a broker) andwe’re having somewhat of a debate about the following phrase from19CFR163.4 (a):  “Except as otherwise provided in paragraph (b) of this section, anyrecord required to be made, kept and rendered for examination orinspection under Part 163.2 or any other provision of this chapter […]

  • EXPORT RECORD RETENTION

    Question: According to CFR Title 19 § 163.5 (Methods for storage of records) specific steps need to be taken in order to be approved to digitize (scan electronically) import documents for record retention purposes.   Can the membership advise on the following?:   Is there a similar requirement for export documents (assuming EAR-99, NLR)?   If so, where […]

  • RECORDKEEPING FOR IN BOND

    Question: Quick question for the membership about record keeping.  Let me preface the question by saying we do not operate an FTZ however we do have a custodial bond.   Through some company re-organization I came across a load of files (7512, HAWB/OBL, Invoices and Packing lists) for in bond shipments.  I’m considering  throwing them […]

  • ELECTRONIC RECORDKEEPING

    Question: I have read conflicting information on notifying customs if you are considering electronic storage of import documents.  I have read a couple articles on the customs website that you must notify customs that your company is moving to electronic data storage.  I have also read on several consulting websites that this is no longer […]

  • EXPORT RECORDKEEPING

    Question: OK, what gives with keeping records of U.S. exports of data that are non-licensable?  Every company I’ve talked to seems to keep records (some sortof log) of data exports which are licensable (BIS license, BIS exception,ITAR license, ITAR agreement etc.).  However, I have yet to find anyone whokeeps records of ALL exports of data.  […]

  • ALTERNATE STORAGE METHOD FOR CBP RECORDS

    Question: We have recently notified reg audit of our intention to store our customs records via an alternative storage method.   (PDF’s on a company network off of CD’s received from our customs brokers)  They have indicated in a letter back to us that we must we must paraphrase (verbatim) all six standards listed in 19 […]

  • EXPORT RECORD KEEPING

    Question:   We are having issues on recordkeeping requirements for export records. Presently we keep our records electronically in a backed up drive. We now have a situation where we have a new situation where we are consolidating large orders. Scanning these larger orders is very labor intensive. We are looking at keeping these orders […]

  • EXPORT RECORDKEEPING

    Our company has global reach and we currently export goods from the States to our Asia Pacific, EMEA and Canadian markets. We currently keep export docs on a Sharepoint site, however with the business growing and changing, our export compliance and the relationship with our export freight forwarder will now be handled by each region […]

  • AUTOMATING EXPORT RECOREKEEPING

    Our export recordkeeping program is somewhat archaic and disjointed – but at the end of the day – we do have access to all of our records if/when asked for. We, as well as our 3PL, keep an ‘export folder’ on each order with hard copies of all pertinent and required documentation as per the […]

  • Tracking Product from Various Countries

    Question: We have small part suppliers who purchase material for us.  These suppliers buy from the most economical source at the time we place our order.   Therefore, the supplier may purchase a part from Country A on one order and purchase that same part from Country B on the next order.  We are trying […]