Question: I just started as import backup at a new company that makes rubber seals/gaskets. Most of our products are EAR99. A customer asked me to send a list of all dual-use items. How do you know if your commercial parts are also being used by some customers for military purposes? How do you determine […]
Question: I just started as import backup at a new company that makes rubber seals/gaskets. Most of our products are EAR99. A customer asked me to send a list of all dual-use items. How do you know if your commercial parts are also being used by some customers for military purposes? How do you determine […]
Question: We are headquartered in the US with divisions worldwide. Our biggest manufacturing facilities outside of the US are in China and India. We manufacture some valves that are considered dual-use according to the CCL. If China manufactures these items and they are not subject to the EAR according to all provisions in § 734.3, […]
Question: In screening a potential customer I ran into pretty good evidence that the individual is posing as an employee of a company that he does NOT work for, which was confirmed by the company represented. He is in the UAE and was attempting to be set up as a customer in order to purchase […]
Question: It has recently come to our compliance department’s attention that our dealer/distributor (whom we’ve received the order from and are invoicing) in the Dominican Republic is allowing their customer (End User) to Route the freight from the US. The End User is IOR into DR. My concern arises with a.) the End User is […]
Question: Sorry if I missed a notice somewhere and if this is an obvious question, but could someone please provide information about these columns? Supplement No. 1 to Part 740-Country Groups / Columns A:5 and A:6 I can’t find any info on them? Are they referenced in certain exemptions? What is designation for a country’s […]
Question: I have a foreign office shipping some items back to our US office. The foreign office wants to put a certain value on these items (the same value that they were originally entered under). But the value after depreciation will be different in the US. Can a transaction have two commercial invoices? An […]
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. […]
