Question: How is anyone in the membership handling imports of steel with respect to TSCA Compliance? How do you determine what is an ‘Article’ for the purposes of reporting to EPA? The guidance from the EPA is not clear. Answer 1: TSCA’s Section 13 Import Certification is not currently required for imported manufactured articles.35 The […]
QUESTION: We have some plastic pieces coming back to USA under American Goods Returned HTS 9801 section (9801.00.1098) We are familiar with this section and very compliant. Our Customs Broker is saying this requires a TSCA statement (for chemicals), but still has to explain why. This shipment has nothing to do with chemicals, nor has […]
QUESTION: Does anyone have a list of HTS numbers where TSCA reporting will be required starting 3/22/19 for regulated composite wood products (see CSMS 18-000727)? ============================== https://www.epa.gov/sites/production/files/2019-03/documents/final_hts_codes.pdf Tricia Stewart MOBIS Parts America, LLC International Logistics & Compliance 10550 Talbert Ave., 4th Floor Fountain Valley, CA 92708 office+ 1-949-468-1601 TStewart@mobisusa.com
QUESTION: Regarding the supplier/vendor certification of compliant TSCA Title VI wooden furniture: 1. Is it acceptable to receive a dated and signed blanket TSCA Title VI certification (on supplier letterhead) from the supplier for their wooden furniture products shipped to the USA or is it necessary to require the supplier provide the TSCA Title VI […]
QUESTION: Regarding the regulations that take effect Jun 1, do they include 100% softwood and softwood products? Or do the regulations pertain only to hardwood? ====================== ANSWERS: Here is a copy o the original Federal Register notice. It states: Does this action apply to me? You may be affected by this direct final rule if […]
QUESTION: When the Toxic Substance Control Act (TSCA Title VI) came out last year, importers could not report goods that were arriving U.S. ports before 12/12/17 as TSCA Title VI compliant. The compliance date was pushed back by one year and the EPA was addressing issues with the trade. Does anyone know what changes […]
QUESTION: If we import a research and development pharmaceutical compound into the US and transmit information to the FDA, can we automatically issue a TSCA negative certification or do we still need to analyze TSCA rules ========== Answers: My opinion is that these are 2 different government agencies that do not share information —- so […]
QUESTION: Who can sign a TSCA certificate? Is this considered “doing Customs business”? *************** Answers: EPA expects that in most cases the TSCA import certification will be based upon actual knowledge of the importer. 40 C.F.R. § 707.20(c)(1)(iii). TSCA Import certification statements may be preprinted, typed, or stamped on the invoice for each […]
Question: We are wrestling with conflicting information on what is the best practice for TSCA certification. First questions: Best case scenario would be to have the supplier provide a TSCA certificate when we are the IOR, for us to use with our entry filing. So the quandary is what to do if the supplier can […]
Question: We are wrestling with conflicting information on what is the best practice for TSCA certification. First questions: Best case scenario would be to have the supplier provide a TSCA certificate when we are the IOR, for us to use with our entry filing. So the quandary is what to do if the supplier can […]
Question: Is there a list of all of the HTSUS numbers that require TSCA Certification? ************
Question: Our supplier is thinking of shipping a small tube of touch-up paint withcertain of their decorative outdoor items so that if the paint happens tochip off, they can touch it up. Does anyone foresee a problem with this?Would the paint get classed with the fountain, itself, under 8413.70? Or,would it have to be broken […]
