QUESTION: With the move by the President to Hong Kong Export Restrictions and Sanctions to be deemed as CHINA, how does this effect normal shipments to Hong Kong companies that are not defense/military shipments. Are these now to be considered under the rule that went into effect June 29,2020 that requires all shipments to China […]
QUESTION: We have an item that we assemble in the US out of dozens of foreign parts from 5+ countries. It seems like this is still simple assembly and would not change the origin based on US definition of Substantial Transformation in case rulings. The component that seems to provide the essence is from China. […]
QUESTION: I’m having a hard time figuring out the related parties criteria for an Export transaction. It mentions the 10% ownership, whether direct or indirect. Could a common parent company fit the 10% indirect ownership criteria making Companies A, B, and C considered related parties regardless of whether they are separate legal entities without direct […]
QUESTION: Has anyone heard when the new proposed regulations for routed exports will be released? ************ Answers: I just talked to Keisha at Census – it is with BIS still for review and synchronization. The BIS and Census rules have to come out on the same day. Census’ draft rule has been done for a […]
QUESTION: I recall there was an FTC ( Federal Trade Commission) rule that prohibits the export of goods that are “unfit for consumption” in the USA. Now I cannot find it on the FTC site. Anyone knows about this rule and if it is still in effect? ================================================================ Answer: Based on my recollection, I think […]
QUESTION: Does anyone now where to find the list of specific documents to retain? I looked in Part 762 but that does not list out to actually keep the copies of commercial invoice, packing list, SLI, SED, signed truck bill of lading and documents of that nature. My boss is requesting the written regulation that […]
QUESTION: I’m looking for a best practice or industry standard for a US export sale and shipment. A customer outside of the U.S. requires either notarized or attested commercial documents used for importation into their foreign country. Who should absorb the fees for the notary and/or attesting service – the buyer or the seller? %%%%%%%%%% […]
QUESTION: With the 25% tariff increase on china material we are shifting a portion of that cost to our International customers by adding a separate line to the sales order. Our Customer in China is asking us to remove this line from the Commercial invoice as it becomes a problem with Chinese customs that the […]
QUESTION: We are planning to export to South Korea some valves and valve parts for Nuclear applications, are there export restrictions not only to Korea but other countries? I would appreciate your guidance as the valves are specifically designed for nuclear applications. ========== Answers: Items for nuclear application are very likely controlled by Commerce, or […]
QUESTION: We received a request from a customer in the Ukraine for a copy of our “export declaration”. The customer said that Ukrainian Customs trusts the value declared on the export declaration more than the invoice used for entry which is why this was being requested. When I asked for clarification and an example of […]
QUESTION: We partner with a few distribution companies in the US who then export our products to different Latin American countries. We would like to cut out the middle man and start shipping to these customers in the Latin America region, but do not know what the size and scope of sales would be. So […]
QUESTION: We sell to a company in the US and they ask us to drop-ship to their customer in Canada. The company that we sold the goods to in the US completes a commercial invoice, lists themselves as the exporter C/O our name and address, and then sends us that invoice to accompany the shipment. […]
