Question: I have a business unit that provides a service of repackaging and storage for their clients. The business unit does not have any title to the goods for they are just providing a service. Since this business unit is providing a service, they are not engaged in any trade compliance activity. If a shipment […]
Question: We (US Company) recently acquired a Swiss company who has active export licenses under their name, we want to dissolve that legal entity name but want to see if those licenses can be assigned to the new parent (US) company name. Does anyone know where to find information about it? ************** ANSWERS: I assume […]
Question: We imported widgets into the US for $10,000 and then sold the widgets to a customer in the US for $20,000. Unfortunately, the widgets are defective and require repair. So as a courtesy to our customer we will re-export the widgets back to the manufacturer for repair. Accordingly, we will file AES. Should the […]
Question: Is there a US Export regulation that states COO marking MUST be on a shipping carton when exporting product from the US? If yes, where can I find that regulation? If yes, would a ‘Made in…” statement on the consumer unit suffice; meaning, there would then be no need for the COO marking on […]
Question: A customer located in So. Korea is purchasing US equipment that will be ultimately sold to their end- customer in China. The purchase item is classified under ECCN 6A005. The export of this controlled item from US to So. Korea does not require an export license, but it would require an export license to China. […]
Question: I’m curious to know, what the membership’s view is regarding the need to obtain End User Certificates (EUC) prior to the export of their products. Do you obtain EUCs for every export, even EAR 99 or do you obtain EUCs for products classified under certain ECCNs (i.e. those ECCNs that have more than AT […]
Question: Does the FPPI letter from the Foreign Principal Party of Interest require an expiration date according to the regulations ************ ANSWERS: No. Authorization is valid until revoked by FPPI. ************ The letter does not have to contain an expiration date. It can be dictated to whatever parameters the shipper/consignee agree. It can be for […]
Question: Could the membership please provide feedback on their experience with issuing export BOL’s to Canada. To whom do you consign the shipment to? The IOR, final destination/delivery address or the Canadian port of entry? IOR is Company B while delivery address is Company C. Should the consignee listed on the BOL be the IOR […]
Question: We export valves controlled by 2B350 (CB2 & AT1) all around the world. I am familiar with support documentation requirements, but BIS frequently asks us to provide a “Business Cert” with our license apps. This document does not seem to be specifically called out in part 748 of the EAR and I am curious […]
Question: We are a US company that ships weekly consolidations to our divisions in Mexico and Canada. We source parts from all over the world, but final-assemble at our US factory into US origin goods. I know that typically when an item is used in a manufacturing process that changes the article into a “new” […]
Question: US parent sells to related UK subsidiary. UK subsidiary sells to end customer in UK. End customer details are known at the time of US export. US parent arranges freight forwarding services from door to door. Cargo will be delivered straight to end customer. Incoterm between parent and subsidiary is CIP London. Freight forwarder […]
Question: We export US-made product to multiple countries around the globe from the US. Occasionally, product must be returned through no fault of our customer. In some cases (i.e. a customer in Indonesia) our customers do not hold a valid export license and therefore cannot act as the EOR from within their country. The goods […]
