Miscellaneous

MISCELLANEOUS

  • Controlled technical data

    OT Fact Sheet: Origin Certification Requirements QUESTION: Could anyone share how your company ensures associates do not access controlled technical data while traveling to arms embargoed countries (particularly China) with a company owned mobile device? Do you prohibit the associates taking the mobile device? Do you create a contractor account with no controlled technical data […]

  • SHIPPING TO SUDAN

    OT Fact Sheet: Origin Certification Requirements QUESTION: Now the BIS has removed Sudan from the State Sponsor of Terrorism list if we sell items that are EAR99 and/or only controlled for AT as long as we do not sell to denied parties are we Ok to sell to Sudan? Do we need a license or […]

  • HTS CHANGES ON SHIPPING DOCMENTS

    OT Fact Sheet: Origin Certification Requirements QUESTION: We export food products from both Canada and the US to over 100 countries globally. In the last few months, we have received requests from International Customers asking us to change the HS code on their documentation.  In some cases, we do not agree with the suggested HS […]

  • BIS LICENSED SHIPMENT OVERVALUED

    OT Fact Sheet: Origin Certification Requirements QUESTION: It’s been discovered that 2 export shipments we made in January had incorrect prices. Our AR department discovered 2 digits on the price were transposed causing the shipment to be overvalued. What are the requirements/best practices in regards to updating the value on our EEI filings to reflect […]

  • SELLING USML AND CCL ITEMS

    OT Fact Sheet: Origin Certification Requirements QUESTION: We stock aircraft parts, some of which are on the USML, some are on the CCL, most are EAR99. We sell these to only U.S. companies; what is our due diligence when determining their plans to potentially sell these to foreign end users? ************* Answers: If you are […]

  • Shipping Items with encryption to Russia

    OT Fact Sheet: Origin Certification Requirements QUESTION: My company has a part that has encryption. We already filed with BIS for a CCAT#. We didn’t receive a CCAT# yet. 30 days have already passed. Can we send the part to customers in Russia? =========== Answers: I would not send it.  I would follow-up with BIS […]

  • Signature Date

    OT Fact Sheet: Origin Certification Requirements QUESTION: Is it ever legal to have the date pre-printed on a Certificate of Origin when it’s used for preferential treatment? ========= Answers: Yes ========== I would have to say no, unless the date and the date of the signature are the same.  The date represents the date on […]

  • Volume declared

    OT Fact Sheet: Origin Certification Requirements QUESTION: If a company imports liquid/bulk shipments, what volume should be declared, the one notated in the BL or the one provided by the inspector that certified the loading quantity and quality? %%%%%%%%%% ANSWERS: Section 151.47 states using gross or net from the Customs accredited commercial lab (inspection co.) […]

  • Drop Shipment for Controlled Item

    OT Fact Sheet: Origin Certification Requirements QUESTION: I have a drop shipment scenario for a EAR controlled item, not ITAR. PO Transaction: –        USA Customer (A) purchases from USA supplier (B).  Supplier B’s warehouse is located in China.  Supplier B places an intercompany PO to China warehouse. –        Customer (A) wants Supplier (B) to drop […]

  • USTR REFUNDS 9903.88.09

    OT Fact Sheet: Origin Certification Requirements QUESTION: In the FR on April 26, 2021, there was a notice that the USTR posted a technical amendment about product imported under 9903.88.09 between May-June 2019  that leave open the possibility of filing for refunds of duties.  I checked my entries and most of the entries have already […]

  • Outsourcing of shipment of corporate gift

    OT Fact Sheet: Origin Certification Requirements QUESTION: Unbeknownst to our logistics and trade compliance team the HR Dept outsourced the ordering and shipment of company gifts given to employees free of charge like tee shirts, hoodies, thermoses, mugs, key chains, hats etc. This is not an issue for domestic shipments.  However, I have concerns about […]

  • Package Labeling

    OT Fact Sheet: Origin Certification Requirements QUESTION: Curious to know how members label their products that are sold in the US- (products could be of US or foreign origin.) ========== Answers: Goods which are US origin are not required to be labeled with country of manufacture.  Goods of foreign origin are required to be marked […]