Export Compliance

Questions and answers about Export Compliance

  • EEI/AES filing for Consolidated shipments for EU country distribution

    Question: Hello: I have a question related to EEI/AES filing for shipments that are consolidated and shipped to one country and are cleared there for distribution to several customers throughout the EU. Would the consolidation be filed as 1 shipment or does each separate package within the consolidation require filing as needed? Thank you in […]

  • Item classification from EU perspective

    Question: Can anyone share your experience on how you identify whether the item is subject to EU dual-use item list (EC 428/2009)? From US export control perspective, we know EAR 734.3 specifically describe the scope and criteria for item subject to EAR, including all item in the US, all U.S. origin item wherever located, Foreign-made […]

  • Ship From/Pickup Location requirements for known export

    Question: We’re listed as the “SHIP FROM/PICKUP LOCATION” on the commercial invoice for some goods that we know will be exported out of the U.S. by our domestic customer.  Our customer acts as the Exporter of Record out of the U.S.  Since we know the goods are leaving the U.S. what obligation do we have?   […]

  • Department of Commerce Site Visit

    Question: Does the Department of Commerce make unannounced visits and if so what type of identification would they provide?   A badge? What is the protocol for when they visit? Answer 1: Yes, they may make unannounced visits, and such a visit could be under a subpoena or search warrant.  They will present formal ID (including […]

  • ITAR-BIS and compliance

    Question: As a company, we are 99% import and 1% export, of which 99% of the time is EAR99.  But there is that one export that may require a license review, or, NLR reviews due to license exceptions, etc…   Because of this rarity, I simply do not have a sufficient number of export events that […]

  • Mexico Drop Shipments for Sales from Subsidary

    Question: My company “A” is trying to establish a direct shipment to our subsidiary company in Mexico “B” and their customers. It has been proposed that we use EXW but I am not entirely versed in which INCO terms are better than others.  I have heard that it is IMPOSSIBLE to use EXW and that […]

  • Is retailer liable for due diligence if customer exports the product?

    Question: We are a US retail company with an export compliance process in which we perform denied party screening, classification, and other export compliance functions once a customer declares their intent to export the product after purchase in case we are viewed as the USPPI.   We also waive the sales tax as part of this […]

  • Drop Shipment shipping documentation

    Question: Drop Shipment question under the following scenario: Incoterm: EXW Factory A) US exporter of record / Seller B) Sold to party in Amsterdam C) Importer of record in Italy (customer of B) B has sold to C at a higher price than A sold to B. I understand that A is the US exporter […]

  • de minimis calculation

    Question: I am working with a company that is interested in exporting its export-controlled design and production technology (entire manufacturing program) for ECCN 6A003 cameras to Japan.  The ECCN 6E001 and 6E002 technical date/technology for the design and production of the 6A003 camera does not require a license for export to Japan, however for many […]

  • Upper Management Buy in

    Question: So wondering how Members handle Compliance Risk and communicating the importance. I just recently (about a year) started a new company lower level position (not Management). Very heavy into Exports and a pretty good amount of Imports. I have many years of experience on the import/export side (20years) Import Heavy, some on the export […]

  • FCC Compliance

    Question: Hi all, New member with what I hope isn’t a stupid question. I’m looking to ship an FDA-cleared device into the US that has yet to achieve FCC certification. We are currently waiting on the results of a waiver request. Is this possible? If so, I’d appreciate it if someone could help with guidance […]

  • Egypt Customs Invoice Item Description

    Question: We are a US based company with a factory in China.  We have a distributor in Egypt who is purchasing OEM equipment from our factory.  The China factory is the shipper, the US based company is the seller. The distributor will be the importer into Egypt. We are selling electronic components that are classifiable […]