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  • FDA Initial Importer

    QUESTION: Our company imports medical devices. Since we import all, we are the IOR. I do not understand whether we are also considered the initial importer under FDA. We occasionally repackage items to send to domestic customers. We are FDA registered for various devices as specification developer or complaint file established. Are we considered to […]

  • Answers to Question on HTS changes

    QUESTION: I am seeing information about new changes to the HTS coming for 2022.  Does anyone have information on this as to what type of changes? ========== Answers: See WCO 2022 HS correlation tables and amendments here: http://www.wcoomd.org/en/topics/nomenclature/instrument-and-tools/hs-nomenclature-2022-edition.aspx ========== I could be wrong, but I do not believe there are details available on this yet.  […]

  • ANSWER TO Question on MID-Codes: buying directly AND indirectly from same MFG

    QUESTION: An importer buys directly from a Manufacturer (XYZ) AND indirectly through a 3rd party Vendor who has partial ownership in the same MFG (ABC) from the same Manufacturer:  should there be 2 separate MID-codes??…  – For the Direct Buy:  one Mid-Code based on the Manufacturer name as (XYZ) AND  – For the Indirect Buy:  one […]

  • Answers to Question on CTPAT Supplier Questionnaires

    QUESTION: For members that are part of the CTPAT program (importer).                                                                                                        When you send out a supply chain security questionnaire to your supplier base and the supplier answers “no” to some questions, how do you handle these types of responses?  For example, do you: Accept the answer as is Respond and ask for explanations.  Once […]

  • Answers to Question on Acquisitions

    QUESTION: The company I work for continues to purchase smaller businesses who operate independent of the parent company, meaning they are retaining their own Tax ID.  I’ve heard them described by leadership as stand-alone companies, we just own them. Because these new companies are owned by the parent company, I do solicit them for C-TPAT […]

  • Importing decor with pine cones

    QUESTION: Does anyone know if any USDA permits are required to import articles that contain real pine cones as decoration such as a Christmas ornament or wreath? If so, which permit? Are there special treatment requirements listed somewhere? %%%%%%%%%% ANSWER: These would fall under the Lacey/APHIS Act. https://www.aphis.usda.gov/aphis/ourfocus/planthealth/import-information additional answer: Miscellaneous and Processed Products Import […]

  • TEMP LABOR AT SELF-FILER

    QUESTION: As a self-filer are we able to utilize an implant from a logistics provider or temp labor to help with our customs entries?  Are there any limitations on the type of work they could perform on our behalf?  *************** Answers: Yes.  A former employer of mine did just that.  Employees of logistics providers or […]

  • AP INVOICE CODING

    QUESTION: When a freight forwarder / customs broker sends a freight invoice, who at your company handles the coding before it’s submitted to AP?  We receive invoices for international freight for export and import, but they can’t be sent directly to AP because they need to be coded so AP knows which account it hits. […]

  • TEXTILE MANUFACTURER IMPORT REPORTIN

    QUESTION: Are there any exceptions to having to report the actual mfg.’s name and address for textile articles?  We will be importing a kit.  It is not considered a kit for classification purposes though, so all items will be broken out.  Two of the items fall under 6307.  The supplier is claiming they can’t supply […]

  • Defense Article Customer no Longer Wants

    QUESTION: Looking for some advice. Defense Article:• USML Category II.a.4• USMIL Category IV.a We received a DSP5 to send a sample launcher to another country. The article arrived at our customer and it was found to be faulty. A new DSP5 was procured to send a replacement article. The replacement arrived and is in working order. […]

  • USMCA PREF D QUALIFICATION

    QUESTION: Does the membership think it’s possible for this item to qualify for USMCA under criterion D?  The producer has issued a manufacturer’s affidavit stating these qualify for USMCA under Preference Criterion D.  We asked for additional support for the D criterion and the manufacturer has stated: Finished item (pet food storage bin) is classified […]

  • Relationship between ECCN and License

    QUESTION: I was speaking with a co-worker from sales the other day and we were discussing the difference between an ECCN that is not EAR99 and a License requirement.   I know EAR99 does not need a License unless the item is being shipped to certain places, people entities etc.   S/He advised that if the item […]