Miscellaneous

MISCELLANEOUS

  • Unmanifested cargo received in error

    QUESTION: The importer received in error an unmanifested package as part of a consolidated entry from its affiliate company in Germany. The package should have been part of a different consolidation headed to Singapore. The goods in the package are worth about $4,000. 1) Can the goods be sent directly on to their final destination […]

  • US CONTENT IN SOFTWARE

    QUESTION: Software is being developed by a non-U.S. company outside of the U.S.  There are U.S. citizens employees, some in the EU, some in the U.S., working on the software.  Does this mean there is some U.S. content in the software? Is the work of a U.S. citizen in the U.S. considered U.S. content? Is […]

  • FUMIGATION CERT DURATION

    QUESTION: Would anyone know the duration for a Fumigation Certificate?  Our overseas vendor had the items fumigated in July, but then was unable to ship due to back-log at origin.  They are wondering how long the certificate would be valid.  Anyone know, or know with whom I should speak?   ========== Answers: A fumigation certificate, also […]

  • Using Microsoft Forms

    QUESTION: Does anyone use Microsoft Forms for vendor solicitation (especially FTA, REACH, RoHS, Prop 65, Conflict Minerals)? What are some positives and negatives to taking this approach? %%%%%%%%%% ANSWERS: The trick is the record keeping and data maintenance by part number.  There are reasonable products that can help you for these projects.  Try looking at […]

  • Foreign Ownership

    QUESTION: Looking for guidance to provide company leadership on the impact of existing DDTC registration IF ownership were to change and equal greater than 50% by a Foreign entity? %%%%%%%%%% ANSWER There is not enough information here to provide solid guidance, but in general everything depends on what the potential organization will look like (structure, […]

  • CONTAINER SHORTAGES

    QUESTION: I am wondering if anyone within the industry has any recommendations on how best to mitigate the challenge of not having containers available for pickup appointments.  We have tried to call the trucking companies assigned the day prior to a scheduled pickup appointment to verify they are able to adhere to their appointment as […]

  • WITHHOLD RELEASE ON SILICA-BASED PRODUCTS

    QUESTION: With CBP issuing a guidance on 6/23 to withhold release orders at all US ports containing silica-based products made by Hoshine Silicon Ind. located in Xinjiang Uygar region, I’m concerned if CBP might do a broad sweep and hold all silica-based products from China. My questions are: Should we request our Chinese suppliers above […]

  • Cryptocurrency

    QUESTION: Does anyone in the membership have information on if there are any export controls around cryptocurrency cross border payments/transfers? *********** Answers: I am not aware of any export controls related to the use of payments based on cryptocurrency for cross border payments/transfers, however, there are some legitimate issues regarding the use of “unofficial” tender/ […]

  • EIN for multiple plants

    QUESTION: I need some guidance on how to set up suffixes for each importing plant instead of all filing under the corporate EIN.  We need to distinguish what import should be assigned to each plant. How is this setup initially?  Through the tax department, finance, etc?  How does it affect the corporate structure, or is […]

  • EEI filings and multiple shipments

    QUESTION: Can anyone point me in the direction of AES or DoC guidance on how to file an EEI for shipments of equipment that is considered to be a system and will be shipped to MX on several different trucks over a few weeks time?   %%%%%%%%%% ANSWERS: This is basically driven by the HTS classification […]

  • 7512

    QUESTION: Regarding our ocean shipments. We have multiple orders shipping out in two containers using one 7512. Is this correct or should each container have its own 7512 for what’s inside of it? %%%%%%%%%% ANSWERS: If this in incoming, into the US, you can have multiple containers on the inbond as long as the master […]

  • GLOBAL TRADE GOVERNANCE CHARTER

    QUESTION: Looking to the community for guidance and/or any documentation on how to develop a Customs Trade Compliance Charter with defined elements of an effective council governance body.  ========== Answer: The charter should cover the risks your looking to control and manage… ===========