QUESTION: My people are arguing with me about our US export recordkeeping requirements. My people say that we do NOT need to get a copy of the air waybill or ocean bill of lading back from the US forwarder legally because we do not “make” it. 762.1(b) says “..all records described in §762.2 of this […]
QUESTION: Qatar customs requires an original, chamber-attested invoice and certificate of origin from the exporting country for import clearance of ocean freight. How do other members manage triangle/drop shipments into Qatar where the supplier is shipping direct from country “A” but the seller is invoicing, with a markup, from country “B”? ================ ANSWER: This is […]
QUESTION: Is it possible to combine goods that are in the USA in a CBP bonded warehouse with non-bonded (customs cleared or US origin goods) and make a single export from the USA (single invoice, single ocean bill of lading, single AES filing?) ======================= ANSWERS: No , full accountability for all merchandise entered into a […]
QUESTION: Many high tech companies within the U.S. utilize the services of Customs clearance agents to act on their behalf, to enter and clear shipments of warrant replacement/spare parts in various countries throughout the world. These U.S. companies do not have an entity in the country and rely on these agents to clear shipments with […]
QUESTION: Name mismatch on end user–license issued with name mismatch but address is the same. Can we ship with the issued license? If not, what needs to be done? ========== Answers: Not sure what you mean by mismatch (maybe misspelling?). Take a look at 15 CFR 750.7. Your answer should be found there. ========== No, […]
QUESTION: I have a question regarding license exception VEU. I’ve received conflicting opinions from colleagues at other companies. We have a customer in China who is not a validated end-user. They want to buy products from us based on domestic orders they receive from a validated end-user. The VEU regulation (15 CFR 748.15) does not […]
QUESTION: I would like to understand what is the industry best practice when reviewing for re-export licensing of non-US origin goods. We procure manufacturing equipment, testers and spare parts that may not be non-US origin. We as the company may not know the how much US content or technology is in the items or if […]
QUESTION: We have a scenario whereby our European related entity requires material from a third party vendor in the US. The third party vendor in the US will not be the exporter of record; therefore, requiring us to perform an intercompany stock transport between the related US entity and EU entity so the US […]
QUESTION: We sell some of our product through 3rd party distributors in other countries. We have a standard export compliance due diligence questionnaire that we send our unrelated 3rd party distributors. One of the questions is: “Do you conduct any screenings against an authorized denied party or restricted party list published by your government, […]
QUESTION: To define the ECCN for Valves that we use for Oil and Gas Production, will it still be under 2B350.g, IF it is NOT intentionally designed for use in Chemical Manufacturing Equipment? We would appreciate if we could get deeper insights into this. ========== Answers: No. You need to analyze the materials […]
QUESTION: If items subject to the EAR are exported to Country A and then subsequently re-exported to Country B, is the re-exporter required to include the Destination Control Statement on their export paperwork? ========== Answers: If the items are U.S. origin, yes. Do companies overseas adhere to it? Most likely not, but I am seeing […]
QUESTION: My company is inquiring whether they can ship a U.S. medical device to a medical trade show in Saudi Arabia where it will be picked up by an Iranian customer. The Iranian customer will then take the medical device back to Iran. I am aware that medical devices can be shipped to Iran under […]
