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. […]


    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 […]


    QUESTION: We have two scenarios for shipments from US to Mexico and are trying to determine the correct Incoterms to apply. 1.       US company to Customer in Mexico – Direct US company pays for delivery to US side of the border, customer in Mexico clears customs and pays for delivery to destination in Mexico. Is […]


    QUESTION: The explanatory notes to 8536 state plugs and sockets assembled with a length of wire are excluded.  What is meant by “a length of wire”?  Is this a certain length or any length of wire? In rulings NY F80658 and NY N299158 why are the connectors with a length of wire classified in heading […]

  • Shipping to Guantanamo Bay Military Base Cuba- OFAC License Exception

    QUESTION: We are being asked to ship EAR99 equipment items to the U.S Military Base in Guantanamo Bay, Cuba I have found the BIS License Exception CFR 740.11 for U.S Govt Agencies (GOV) but after checking OFAC website and 31 CFR 515 Cuban Assets Control Regulations cannot find any evidence of an OFAC License exception […]

  • FDA Physical manufacture vs legal manufacture for medical device imports

    QUESTION: Just trying to figure out, if you are importing a medical device under FDA intended use code 081.001. For manufacture reporting at the time import to FDA, do you have to report the legal manufacture or the physical manufacture.  What if the legal manufacture(distributor) is in a different country than the physical manufacture? But […]


    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 […]


    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 […]