QUESTION: I have recently joined a company that has numerous routed export shipments of EAR99 goods. When I say they are routed, the product is delivered to warehouses in Miami, and the foreign buyers work with their US agents to consolidate product with others for main carriage to the final destination. The current process is […]
QUESTION: I’m hoping the ICPA community can provide their guidance on this one. We are a foreign entity in the Netherlands that performs various types of defense services on ITAR controlled military hardware (both SME and non-SME). We were recently added as a sub-licensee under a Technical Assistant Agreement (TAA) in order to perform a […]
QUESTION: I have a dilemma in determining who should be the true exporter of record. My company has an office in West and East Coast. The West Coast office is the physical distribution and export for two different divisions/product lines. We have always exported under West Coast office address and TAX ID. Internally we will […]
QUESTION: My company imports into the US and then exports some of the products into Canada, so I want to look into setting up a duty drawback program. To determine the potential refund amount, I can run the ACE ES-003 report to see the details of all our US imports, but how can I find […]
QUESTION: Asking for any experience people are willing to share of interaction with Czech Republic Customs authorities about the declaration of Country of Origin (CoO) for materials being exported. I am aware of the requirement to declare accurate CoO and that this data is coming under more focus recently due to various trade sanctions. We […]
QUESTION: I know the rules require claiming both ‘D’ or ‘F’ for origin when items of the same HTS code are exported. We manufacture and buy a bulk commodity, but do not have an inventory system to identify how much of the exported fungible good was from a foreign source or a domestic source. Is […]
QUESTION: I have a client who is interested in finding cheaper options for transporting product to the Caribbean Islands from Panama. The client suggested to bring the containers to Miami, then transport it through a 7512 “in-bond’ to Everglade, FL where the product would be repackaged and sorted into different containers, then transported back to […]
QUESTION: We buy products and parts from US vendors and need to export, and those civil products obviously belong to EAR99 and we don’t see any possibility of dual use. However, we have recently learned that the product contains a couple of circuit boards (PCB boards) which had hundreds of various electric components soldered on […]
QUESTION: Company “A” is buying from Company “B” – Company “A” is exporting the goods to Company “C” overseas – In my experience Company “A” is the Exporter – Correct or incorrect? %%%%%%%%%% ANSWER: Maybe. Maybe not. Not quite enough information to go on. Assuming both Company A and Company B are in the […]
QUESTION: During a review of ACE Export reports we noticed that some “routed exports” were actually flagged as standard exports. Is this considered a “violation”, and do the EEI/AES filings on these exports need to be corrected to indicate that they were actually routed exports? Clearly this needs to be addressed with the FPPI and […]
QUESTION: Company “A” is buying from Company “B” – Company “A” is exporting the goods to Company “C” overseas – In my experience Company “A” is the Exporter – Correct or incorrect? ========== Answers: If Company A and Company B are based in the same country and that sale is a domestic transaction, then it […]
QUESTION: 15 CFR 30.6(a)(2) says the date of export is “date when goods are scheduled to leave the port of export on the exporting carrier that is taking the goods out of the United States.” When a carrier rolls that date, is the filer obligated to amend the EEI with the revised date? More specifically, […]
