Question: Would the members consider access by US person employee to technical data or technology on the US company’s network via VPN from outside the country an export if no non-US persons are given access? (Is the data really leaving the US?)
Question: Can anyone help me find a quick way to get Russian Regulations either in English or Russian?
Question: The question sounds like it involves an FCA (customer’s forwarder) situation. In all cases, seems like the answer is that the customer’s forwarder needs to be filing EEI on the FPPI’s behalf. Perhaps I should pose the question, what about the INCOterm saying shipper is responsible for clearing for export? How does that impact […]
Question: We received product back from a UK customer that they wanted re-tested to a tighter specification. The product itself did not change form, fit, or function – it was simply re-tested (service). We considered this to be a repair, and were sending it back out under 9801.10.0000 with a declared value of the […]
Question: Anyone seeing a phrase like the following that I have showing up in an L/C from an EU subsidiary to a Pakistani customer?: “Transshipment is prohibited through Iran, Cuba, North Korea, Sudan, and Myanmar.” I cannot track down where this phrase is coming from, any thoughts? It appears to be an […]
Question: We currently supply to our Argentina distributors disposable masks with the schedule b of 6307909995. These are manufactured in Tunesia. Our Argentina distributor states we must provide the following for them to be able to import them into Argentina. A certificate of origin, original or copy, from Tunesia to the us here […]
Question: In a Routed Transaction, the USPPI [beneficiary] is obligated to provide certain data elements that will allow the FPPI [foreign buyer] or their designated freight forwarder to correctly file an EEI via AES. In our case, those elements are provided on our invoices and a Routed Transaction Shippers Letter of Instruction. This information is […]
Question: Is there anyone in the trade community that can advise if their export compliance program has went through an internal legal verification. I am in the process of developing an export compliance program for my company. The changes required to fully implement our program will be costly and time consuming. Prior to making […]
Question: If we have an export of two items that fall under the same US HTS# but are both of different origins, say hypothetically $1500 USD worth of TW goods and $1500 USD of US origin goods…. Would we have to : A) Not file an EEI because the values of both items are under 2500 […]
Question: We are looking for some input on how companies identify routed exports on Bills of Lading and/or Shippers Letters of Instruction. We are a manufacturer who has recently changed networks into Latin America. Now many customers are buying FCA or FOB to forwarders in Miami. These shipments are thus routed exports. Question is […]
************************************************************************* _____________________________________________________Question:I was wondering what kind of liability an exporter to country A has, if they know that the end product will be re-exported by their direct customer to Country B, as far as ensuring licensing is not needed (for the final destination). My understanding is that we have a responsibility to know what the […]
Question:Is anyone outsourcing the filing of the EEI’s? My company wants me to look at having an individual in another country (working 3rd shift their time) to file EEO’s for our shipments from the US? Thoughts? *****************************************************************
