QUESTION: How many USPPI’s obtain documentation of EAR Sec. 758.3(b) assumption of licensing authority from the FPPI in routed transactions? ========== We have wording on our end use / end user forms stating the FPPI is responsible for any license determination. With that said, almost 99% of my exports are EXW and routed transactions. I […]
QUESTION: Our company exports and files the EEI from different locations with same EIN, when we obtain the export reports from ACE it is a lot of work to identify the export location because it the same EIN. One of the suggestions from the compliance team is to identify each location with a suffix example: […]
QUESTION: One of our distributors in Russia is asking for the name of the physical manufacturer for our parts that are not US origin, saying that on the customs declaration, they have to list the producer in the country of origin. This is for items in a variety of HTS numbers. They are mostly spare […]
QUESTION: 1. We ship software/hardware. The software/hardware has cryptographic capabilities that would typically make it classified under 5A002 or 5D002. However, the customer cannot access/use the cryptographic functions without a separately sold license key code. Would the software/hardware be classified under EAR99? 2. When we sell licenses to our customers that allow them to access […]
QUESTION: I am hoping some guidance can be given for Routed Transactions, and what others consider to be due diligence for attempting to have corrections made to EEI filings (all EAR99 products). The error could be the USPPI address, or adding Inc or LLC to an entity name, or not placing the correct gross […]
QUESTION: Really struggling with new categories. ECCN 7A611.x to Australia under 100.00 shows LVS as an option. AES gives error saying it is not authorized under this exception. I cannot get anyone to explain why, it looks to be allowed per the EAR. Any thoughts? ========== Answers: How new is the LVS exception to this […]
QUESTION: I read the destination control statement on the invoice from 15 CFR Sec. 758.6 to in effect/by implication require that the ultimate consignee be identified (name, address, country) on the invoice (unless EAR99 items). Has the membership faced any pushback/requests from foreign customers (e.g. re-sellers) not to include (to remove) this ultimate consignee information […]
QUESTION: We have always handled only ITAR, now some items have moved to EAR. We import parts from a foreign supplier, some were defective and need to be replaced. License exception RPL does not seem to fit this circumstance. Any guidance? ************* Answers: You may want to also see if Return of Foreign Origin Items […]
QUESTION: We have Export Shipments to Related companies in South America. Incoterms they mandate are : CIF to their Named Warehouse Address Appreciate members explaining how they manage CIF for shipments exporting to South America, specifically the Freight Costs on the Commercial Invoice. Our Questions Include: Actual Freight Costs to be included ( Do you use the […]
QUESTION: We currently have a record retention policy in place that states “5 years for import and export documentation” and “10 years for shipping invoices” The problem I am running into is that we have our shipping invoices and our pick slips (which is part of the 10 year retention requirement for our company) mixed […]
QUESTION: Do two items with the same HS/Schedule B *but* with different ECCN’s have to be reported as .separate lines on the EEI? (We will assume here that each item is valued at over $2,500) (The FTR does not address this, at least not explicitly.) ========== Items with the same HTS/Schedule but different ECCN’s should […]
QUESTION: I have been tasked with creating and managing an export compliance recordkeeping system/procedure. We have Sales Representatives (independent contractors) that represent and sell our products all over the world. Are these Non-US citizens, selling US origin products (manufactured in the US) subject to the recordkeeping requirements of BIS part 762? ========== Answers: Yes ========== […]
