Miscellaneous

MISCELLANEOUS

  • CBP LIQUIDATED DAMAGES

    QUESTION: I received a liq dam for untimely payment of duty in the amount of roughly $100.  Option 2 on the liq dam states I can petition but if I lose customs can increase the fine.  Where is the regulation stating how much customs can add to the original $1,000 penalty? I am told that […]

  • MULTIPLE SUPPLIERS FOR SAME PART

    QUESTION: I am wondering about the best practices when a part can have more than one supplier. How do you handle it? Which supplier/origin are you considering? ************ Answers: there are really only 2 ways: 1 – create separate part #s – so it’s a dash 1 for Netherlands origin and dash 2 for China […]

  • Parts Control Plan

    QUESTION: We have received several requests from BIS DOC for customers to provide a Parts Control Plan.  We want to get our hands on a sample PCP to share with the customers.  Hoping someone can assist to provide an example of a PCP. =========== Answer: Fully aware I’m stating the obvious, but your customers should […]

  • Demurrage chargebacks to the customer

    QUESTION: Can the membership please provide some thoughts and direction in regard to outrageous chargebacks for demurrage. Five invoices with backbreaking charges for demurrage. How is this in any way the customer’s responsibility when the freight forwarder and its chosen trucker are unable to pull the containers out in a timely manner (through no fault […]

  • Tariffs on FOB basis

    QUESTION: I’ve read that the United States is one of the only countries which assesses tariffs on an FOB basis as opposed to a CIF basis, in other words freight and insurance cost is not factored into duty calculation on US imports. Can anyone provide a current list of countries which assess tariffs on an […]

  • ITN info

    QUESTION: We have a small logistics and import/export team with no physical presence in thee countries in which we have related party entities so the US team support logistics globally Our related MX entity purchased some equipment from an unrelated US partner under INCOTERM FCA-mfr location.   The US seller/exporter filed the EEI through its broker/FF. Our […]

  • E-COM SHIPPING AND COO

    QUESTION: Kindly comment (non USMCA items):  Under CFR134, the Ultimate Purchaser in the US should be able to know the COO of the SKU.  In many cases, the importer may import the same SKU from multiple countries of origin…as long as the markings of the box and item follow CFR134, all should be fine since […]

  • AUDITING THIRD PARTY IOR PARTNER

    QUESTION: I wanted to ask to those members using the services of a 3rd party importer of record (IOR) provider to clear the shipment through the relevant customs jurisdictions, pay all applicable import duties, taxes and fees; plus assume all legal responsibility for the import. How do you audit their trade compliance relevant practices?  We need […]

  • 2022 HTS CORRELATION TABLE

    QUESTION: Does anyone have an HTS correlation table in Excel related to the WCO 2022 tariff changes? =========== Addl Answers: I’d touch base with your own broker(s) to ask what they can provide =========== Kindly see the enclosed Document. Hope it helps, https://www.icpainc.org/wp-content/uploads/2021/10/WCO-2022-tariff-changes-1.pdf =========== See attached Excel sheet. Suggested changes only, you are responsible for […]

  • Human labor due diligence

    QUESTION: We have a difficult time getting some vendors to sign the code of conduct provisions as part of our vendor set up requirement.  The ones that refuse to sign are bigger companies, usually publicly traded.  Would anyone like to share your current due diligence process for working with domestic vendors?  Our foreign vendor have […]

  • Huawei LTE phones

    QUESTION: Can our foreign owned entities that are subject to US law, e.g. OFAC, BIS, etc… purchase Huawei phones for business use and not be in violation of the US sanctions on Huawei? ========== Answers: You just answered your own question:  “Can our foreign owned entities that are subject to US law . . .” […]

  • Imports into Egypt

    QUESTION: We are a semiconductor manufacturer with locations around the globe. We are importing chips and PCBs into Egypt for design and development but are constantly running into lengthy delays at Customs for inspections and reviews by the relevant authorities. Is anyone in the membership doing business in Egypt and might have suggestions on how […]