China

Questions and answers about China

  • MID for unknown manufacturer?

    Question: Odd question – how do you create a MID code if the manufacturer is unknown?   We acquired thru a lawsuit an item that was used to manufacture counterfeit versions of our product in China.  The item is in possession of one of our authorized manufacturers in China currently.  We would like to import it […]

  • PRC MOFCOM End User Statement Export Value

    Question: Hi Everyone!  My question is for interpretation of the value limit in 15 CFR 748.10(a)(3) for requirement of a PRC End User Statement. The requirement says “Any commodity(ies) requiring a license to the PRC for any reason on the Commerce Control List, and the total value of such commodity(ies) requiring a license exceeds $50,000.” […]

  • US Companies Sanctioned by China

    Question: Does anyone know where to find a comprehensive, updated list of US companies that China has sanctioned? Answer 1: Opensanctions.org has three lists: Chinese Unreliable Entities List (UEL) – OpenSanctions Here are their names in Chinese. That may help with a Baidu search. The Unreliable List – 不可靠实体清单 The Countermeasure List – 反制清单 The […]

  • Software media shipments to Chinese customers required to

    Question: Hi All I work for a software company. Customers download their software and keys from a secure website. I inherited a process that’s causing me some concern – if a customer requests it, we will send them their software on media (DVD or USB drive) in addition to making it available for download.  All […]

  • China and Commercial Items 7A994 and 7D994

    Question: Good morning, members I recently started working for a new aerospace company that mainly does commercial items that fall under 7A994 and 7D994.  The only control for those items is AT but some of our sales are to Chinese and Venezuelan Civilians (no military).   Can we still use NLR as both countries are not […]

  • 744.23 Semiconductor manufacturing equipment & FDP Rules

    Question: I have a foreign made item that I have determined is not subject to the EAR based on FDP rules. The item is EAR99 and all items in the bill of materials are EAR99 so therefore there is no controlled US content. This item is used for gas and chemical delivery systems incorporated into […]

  • EAR 15 CFR 744.23(a)(1)(v)

    Question: Greetings! I work for a company that manufactures EAR99 items that contribute to “The “development” or “production” in the PRC or Macau of any “parts,” “components,” or “equipment” specified under ECCN 3B001, 3B002, 3B090, 3B611, 3B991, or 3B992.”. Since the new regulations of 744.23 in Oct of 2022 I have received mixed responses from […]

  • Temporary Import

    Question: I had a discussion with a customer that is looking to import some material from China to Mexico but would like to take possession of the material at a US port and then import to Mexico.   We will drop ship the product from China.  The customer claims that since it is a temporary transaction, […]

  • UFLPA ACE Enhancement Region Alert Information Notice for Trade

    Question: UFLPA ACE Enhancement Region Alert Information Notice for Trade (cbp.gov) In the publication from CBP of Nov 2, (link above) listed what will change for trade users, wondering if the trade is interpreting the below item in italics / bold, meaning any time a shipment of CN origin, it will be required to provide […]

  • UFLPA compliance and supply chain due diligence

    Question: We buy product DDP from a Chinese vendor.  We do not source the fabric or any of the buttons etc.  We simply buy the garment that the vendor designs.  We learned recently during a supply chain review that the source of the fabric and yarn is Xinjiang, China which is subject to the UFLPA […]

  • Export from China

    QUESTION: A facility in Europe wants to import parts from China, the supplier says it is not able or doesn’t have any certifications to export out of China. How can we get export documents in this case? Are there any exports restricted by China? If so, where would I find a list of what those […]