Export

Questions and answers about Export

  • Export ECCN

    QUESTION: We are currently looking into our new technology that is coming out soon and have questions on license determination.  If we have WIFI or voice controls on our finished goods, could this change our ECCN from EAR99 possibly to 3a001 or other classification?  We do not export these as parts but are included in […]

  • VALUATION OF ITEMS EXPORTED FOR REPAIR

    QUESTION: We are going to begin exporting damaged/unusable nozzles to a company in Canada who will refurbish them and return them to the US. We are providing the used nozzle at no charge to the repairing company, who is charging us only for the costs of the repair. What value should be used on the […]

  • Routed export transaction

    QUESTION: For a routed export transaction (FCA terms, customer arranged transportation) from Singapore to Malaysia, who is responsible for export permit / declaration?  Please include regulatory citation, if applicable. ************ Add’l answer As other have already indicated, a “Routed Export Transaction” is a U.S. concept so it has no bearing on this transaction based on […]

  • Recourse for erroneously canceled EEI filing

    QUESTION: Scenario: EAR99/NLR goods exported from US and consigned to affiliate in Nicaragua EEI filed based on $2500 value/HTS and COO indicator One day post-export, USPPI reaches out to forwarder to halt export to NI and to reroute to MX Before getting confirmation from forwarder, USPPI immediately canceled EEI filing for NI and filed EEI […]

  • AUTH AGENT UNDER 30.3(e)

    QUESTION: I’ve seen a lot of emails regarding Routed Export Transactions the responsibilities related to the EEI filing.  It’s piqued my interest. It’s clear that 30.3(e) provides instructions for who files the EEI.  The FPPI authorizes an agent or the USPPI to file, it does not mandate them. The questions I never thought of until […]

  • Export

    QUESTION: As an exporter, do we need any type of license if we want to book our own shipments, send our bill of lading instructions and file our own AES instead of using a forwarder? ========== Answers: No.  You can file EEI yourself once you setup the account and have been approved and you can […]

  • Export Transactions

    QUESTION: We are a USA company selling goods to a USA company, but due to time constraints they want us to export the goods directly to their customer through our freight forwarder. Since we sell to them at one price but they are selling the goods to the ultimate consignee, we are not part of […]

  • EXPORT LICENSE SCENARIO

    QUESTION: The company I work for is bidding for new business.  The company they are trying to win new business from is looking for an Export License from us.  Is there a particular document that states “XYZ Company has the authority to ship international” ?  The company I work for is global and we ship […]

  • UNKNOWN END USERS VIA DISTRIBUTORS

    QUESTION: We have a manufacturing plant in the US. We own divisions and subsidiaries in 30+ other countries that order from the US factory. Our export compliance policy requires End User info for all exports, regardless of whether it’s to a related entity or not. Is there any leeway here with related entities, for example […]

  • Customs Declaration Revision in China

    QUESTION: Recently we imported a containers worth of products into China where about $15,000 worth of parts from one supplier were not mentioned on the commercial invoice.  This discrepancy was not discovered until the container was unloaded at our factory.  Now we have an issue as it relates to the payment of the supplier of […]

  • routed export transaction

    QUESTION: For a routed export transaction (FCA terms, customer arranged transportation) from Singapore to Malaysia, who is responsible for export permit / declaration?  Please include regulatory citation, if applicable. ************ Answers: “Routed export” is a U.S. concept.  In Singapore the exporter is typically responsible for the export permit and reporting. ********** Routed exports are part […]

  • INCOTERMS AND EXPORT FILINGS

    QUESTION: As per the U.S Census, Incoterms cannot be used to determine who is responsible for filing Electronic Export Information. The Foreign Trade Regulations do not support incoterms, and I understand that Incoterms isn’t a US laws, but on how you can understand “Export Clearance” mentioned on incoterms? ========== You can’t.  Commercially speaking, if it is your responsibility […]