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  • NAFTA RVC CALC TEMPLATE

    QUESTION: Does anyone have a NAFTA RVC calculation sheet to share? In addition to material cost, what else does your calculation formula include- an amount for labor,overhead? What else? ************* Answers: Assuming you are asking about calculating the net cost, per US HTS General Note 12D(vi), the producer of the goods may calculate the total […]

  • Routed exports practices

    QUESTION: We make several hundreds of FCA, customer pick up shipments a month, all items that we sell are EAR99. We have a global ERP system and these orders are placed by the overseas customer service on the US branch plants, they also generate CI and SLI for their customer and coordinate cargo pick up […]

  • ARRA Buy American and 52.225-11 BUY AMERICAN–CONSTRUCTION MATERIALS UNDER TRADE AGREEMENTS

    QUESTION: My questions are regarding the difference between the ‘ARRA Buy American’ and the ‘52.225-11 BUY AMERICAN–CONSTRUCTION MATERIALS UNDER TRADE AGREEMENTS (OCT 2016)’. 1. Are the ARRA Buy American provisions still active, or has this been dissolved? It looks like more funding was added to keep it going. 2. Are ARRA Buy American and 52225-11 […]

  • Can I claim FTA for a repaired unit being sent back?

    QUESTION: We have goods returned to us periodically that need to be repaired. The items are made in the US and the initial export/import to the foreign country qualify for the appropriate FTA. We repair them in the US and use either US made components (by us or suppliers) as well as components/parts that may […]

  • POST-BREXIT HTS CODES

    QUESTION: My understanding is that in the event of a hard Brexit that the UK will use the same HS classifications as the current EU classifications for imports into the UK, and for duty rates use the WTO MFN duty rates. Does anyone have any different understanding? ========== Answers: ========== This is correct for the […]

  • VENEZUELA BLOCKING

    QUESTION: I’m going cross eyed reading Executive Orders. Is the current status of the Government of Venezuela that it is only subject to the financing restrictions of EO 13808, but is not BLOCKED entirely? ========== Answer: Read 31 CFR 500 for any Treasury questions https://www.ecfr.gov/cgi-bin/text-idx?SID=4544ae6adea84a6f1cda56716c045a46&mc=true&tpl=/ecfrbrowse/Title31/31cfrv3_02.tpl#0

  • HTS & VALUE FOR DONATIONS

    QUESTION: Does there exist an HTS code or valuation method for defective goods solely for donation? Any suggestions? We have a situation in which a container-full of jackets have quality issues and can’t be sold to the public. The overseas factory we shipping the product directly to the USA-based charity, and we will be importer […]

  • FDA IFE-Import For Export

    QUESTION: I am stumped. If I were to use the FDA’s Import For Export (IFE) program I would use the Intended Use Code of 970.001. One of the mandatory Affirmation of Compliance is LST (Device Listing Number), but the product is not listed with the FDA, so if I do not have an LST, the […]

  • USML FOR CAPACITORS

    QUESTION: 1. Are capacitors that are clearly designed for commercial applications can meet the criteria of ITAR USML Category XI(c)(5), or only capacitors that are specially designed for military applications are controlled under ITAR USML Category XI(c)(5)? This is asked even that ITAR USML Category XI(c)(5) have only technical parameters and not the “specially designed”. […]

  • FILING EEI FOR US TO GUAM SHIPMENTS

    QUESTION: Have a question regarding exporting to Guam. The commodity we are exporting does not require a license but it is over $2500 in value. Are we still required to file EEI. Since Guam is a territory of US. Per 15 CFR 30.2. Are there any special regulation to exporting to Guam. *************** Answers: No. […]

  • MTB

    Add’l Answer: You can hire counsel if you like spending money. But if your product meets the requirements listed in the MTB, you are allowed to claim the MTB. We claim a MTB which we did not request, I reviewed the provisions, checked off the boxes that it qualified and then I informed our Account […]

  • New CTPAT MSC

    QUESTION: I was wondering how the membership is preparing for the newly published CTPAT MSC’s. Specifically, I would like to know: • Does anyone already have a template they can share with a statement promoting a culture of security and affirming commitment to supply chain (Section 1.1) • For the cross-functional committee team, what management […]