QUESTION: May a person subject to U.S. jurisdiction export or reexport to Cuba items that include U.S.-origin content, but are not 100 percent U.S.-origin? Persons subject to U.S. jurisdiction may engage in all transactions ordinarily incident to the exportation or reexportation of 100 percent U.S.-origin items from a third country to Cuba, consistent with the […]
QUESTION: Can anyone in the membership advise if an HTS number is required to be on the U.S. shippers commercial invoice for an export going to S. Korea? ********** Answers: It is not “required” by any USA agency to be on the export invoice. However, often companies do put the HTS on the export invoice, […]
QUESTION: When filing an EEI with multiple line items under the same Schedule B Number, often times the EEI filing has different nomenclature than the items on the commercial invoice. For example the EEI filing may state “simulation training equipment” rather than listing the name of each item. Does anyone know of a BIS regulation […]
Question: A US aerospace company contracts with an Indian engineering services company to perform should costing services using US supplied technical data and India supplied should costing software. India then returns the data to the US company along with the should costing results. Note that the data is not altered in any way – only […]
Question: US Company exporter knows 2 FACTS: 1) The part /component you export from the USA will be incorporated into a foreign origin item NOT subject to the EAR (i.e. beneath de minimus) 2) The foreign end item (that is not subject to the EAR) will be exported to Iran. Is this OK, since the […]
Question: Exports to Israel from Malaysia are technically illegal, right? Yet MILLIONS of dollars worth of goods make that trip every year. How are they doing it? Is it legal? Or are we talking gray area ========== Answer: I have done a bit of work in the area if you would […]
Question: We are a U.S Company with subsidiaries and employees worldwide. We have a division that only focuses in Intellectual Property (trademarks & patents) worldwide. So far all of the products we have sent to SNAP-R have been classified with ECCN # EAR99. We just acquired a new brand of products (Pesticides) that are […]
Question: The Exporter/USPPI should be screening many parties to the export transaction. My question is what does a freight forwarder screen? I can only think of what is mentioned on the AWB or SLI (Shipper, Intermediate Consignee, and Consignee), if names (Individuals) are provided, than those names are screened. So the screening to a […]
Question: Does anyone have a corporate level Export Compliance training deck that can be shared with the membership? I’m working on one for my company and want to make sure I’m covering all the information that is pertinent to the “general population” in the sense of Export control awareness. ============================= ANSWER: The awareness […]
Question: My U.S. based company sells medical devices that are listed on the ITSR list of medical exceptions. If we intend to use the General License to ship to Iran, do we need to file anything in advance with OFAC to get their permission to ship? Or, can we ship without specific permission using […]
Question: Our company offers online and instructor-led courses and we are looking for guidance on classifying those courses for export. The subjects of our courses involve the operation of various types of sophisticated IT software and IT hardware (networking, servers, etc). The audience for our courses are software engineers or IT technicians. Some of […]
Question: I’m trying to determine if a BIS license must be filed with CBP the port of export or whether it can be filed with any port nationwide. What is the requirement? Additionally, is it documented in 15 or 19 CFR? ******************** Answers: Are you mistaking BIS with DDTC (who used to require “lodging” of […]
