Export

Questions and answers about Export

  • CCATS FILING FOR FOREIGN ENTITY

    Question: Could we, as a US company, submit a CCATS ruling on behalf of another (foreign) entity? We need ECCN classification for software from a small German vendor who is clueless about US export controls. We’re unwilling to classify the software ourselves b/c of potential controls, but we wouldn’t mind assisting with a CCATS application. […]

  • EXPORT SCREENING DILEMMA

    Question: I am responsible for approving customers for my company.  I must screen the contact and company via our screening software and obtain an End User Cert completed by the customer in order to approve them.  I have encountered a few different parties which appear to represent that they work for a company that they […]

  • CCATS FILING FOR FOREIGN ENTITY

    Question: Could we, as a US company, submit a CCATS ruling on behalf of another (foreign) entity? We need ECCN classification for software from a small German vendor who is clueless about US export controls. We’re unwilling to classify the software ourselves b/c of potential controls, but we wouldn’t mind assisting with a CCATS application. […]

  • ROUTED TRANSACTION

    Question: Scenario: Foreign Buyer (FPPI and Ultimate Consignee) purchases goods from a US Vendor.  FPPI controls the movement of the cargo and instructs US Vendor to ship the goods to a US Warehouse unrelated to US Vendor.  The US Warehouse is used by a related US company of the Foreign Buyer.  The goods will be […]

  • EXPORT SCREENING

    Question: Does anyone have very specific screening procedures/policy which you would be willing to share? I often have a difficult time choosing where I draw the line regarding the end of my research/due diligence on a given party to be screened. Do you strictly screen the individual name of the customer point of contact and […]

  • DEMO EQUIPMENT SENT TO CANADA

    Question: Our company has a fleet of product demonstration vans that travel the US loaded with product (hand tools) and giving product demonstrations to potential customers. We are preparing a similar van for use in Canada, but have had some demonstration possibilities come up before the Canadian van will be ready. We are trying to […]

  • OFAC SDN LICENSING

    Question: At http://export.gov/ecr/eg_main_023148.asp, it states that parties listed on OFAC SDN with certain designators (SDGT, SDT etc.) are subject to EAR licensing. I had “assumed” all on the OFAC list would be subject to OFAC licensing.       1)     Does it say this in the EAR anywhere? 2)      Are all the other […]

  • 9801.10 FOR EXPORTS

    Question: Using 9801 when importing U.S. Goods Returned is optional.  If you want to pay duty, CBP won’t complain. But can anyone confirm whether the use of 9801.10.0000 is optional when reporting the export value of repairs in AES? Can we use the “normal” HTS/Sched B if we want? Section 30.29 in the FTR uses […]

  • DEEMED EXPORTS

    Question: I need a clarification on the Deemed Export Regulation. We are a distributor of medical products and our Distribution Centers are used for storing  products and not manufacturing them. When foreign nationals visit our DC’s for a tour or for a sales meeting, are we required to report these visits ? *************** ANSWERS: First […]

  • EXPORT SCREENING IRAN AND SUDAN

    Question: Does anyone use the various participating US State “Iran Divestment and Sudan Scrutinized Companies” lists as part of their denied party screening? If so, how do you determine whether or not an actual match is a true export compliance risk for your company? Do you block these or clear these? These lists include most […]

  • SHIPPING TOOLS TO CHINA

    Question: My company needs to ship used tools/molds from our manufacturing site inthe US to our new manufacturing site in China.There are not hand tools rather tools that mount on our our molding lines.Tools are bought and paid for by our China based customer. We are”localizing” production now to China that ourWe are being asked […]

  • AES RE-EXPORT VALUE

    Question: When we import something invoiced in Euros, our broker uses an exchange rate on the 7501 to get the entered value in USD. If, let’s say, we want to re-export that item in the same condition as when imported, what should we use as the export value? Should we use the same exact USD […]