Miscellaneous

MISCELLANEOUS

  • RESTRICTED PARTY SUMMARY DOCUMENT

    QUESTION: I am working to create an at-a-glance document to help explain internally to our global stakeholders who all the U.S. government entities are that issue the denied/restricted/sanction lists, what their reach is, and what the implication of the lists are.  Probably more than the one page high level document that I envision, but I […]

  • EIDR and CFSP Application in the UK

    QUESTION: Looking for help from the membership. We are in the process of submitting our EIDR and CFSP application (Simplified Procedures) for our imports into the UK now that we finally received our DAN.  Part of the application process looks to be the need to submit written procedures on the following: Written procedures You must […]

  • MID-Codes: buying directly AND indirectly from same MFG

    QUESTION: An importer buys directly from a Manufacturer (XYZ) AND indirectly through a 3rd party Vendor who has partial ownership in the same MFG (ABC) from the same Manufacturer:  should there be 2 separate MID-codes??…  – For the Direct Buy:  one Mid-Code based on the Manufacturer name as (XYZ) AND  – For the Indirect Buy:  […]

  • HS AND HTSUS DIFFERENCES

    QUESTION: I ran across an anomaly in the tariff recently relative to heading 8303.  The HTSUS differs from the Harmonized System Convention. • HTSUS: Armored or reinforced safes, strong-boxes and doors and safe deposit lockers for strong-rooms, cash or deed boxes and the    like, AND PARTS THEREOF, of base metal. • HS: 83.03   Armoured or […]

  • SLI IN EXCEL

    QUESTION: I’m tired of filling out so many different formats of SLI. Does anyone have a sample general one, maybe in Excel, that I could customize for my company? ************** Answers: Attached .pdf and .doc formats. https://www.icpainc.org/wp-content/uploads/2021/03/ICPA-shipper_export_dec.pdf https://www.icpainc.org/wp-content/uploads/2021/03/ICPA-SED-form.doc **************** The NCBFAA has an industry standard SLI posted at its website.  Either search on “NCBFAA SLI” […]

  • OCEAN FLASH TITLE TRANSFER

    QUESTION: Can anyone in the membership share a sample contract clause addressing title transfer at a (named) longitude and latitude location in the ocean? ***************** Answers: I think you need much more than just a contractual agreement, you need to address issues around the ocean negotiable B/L for example as this is considered the title to […]

  • Practical Work Experience Import/Export Field

    QUESTION: Looking for advice from the membership about how to obtain work experience in the import/export industry and best method(s) to approach a potential career move. I’ve spent the last 5+ yrs. attaining the broker license, attending workshops & courses to learn/hone classification skills, NCBFAA CES, etc. Yet, when perusing job openings and calculating my […]

  • Use of SPI C#

    QUESTION: Taking into account CSMS 14-000077, we understand that goods entered under Civil Aircraft Agreement that are marked or eligible to be marked the “product of” a country (let’s say Mexico in this case) with which the U.S. has an FTA that provides MPF exemption (let’s say USMCA in this case), can be imported free […]

  • NON-EXPORT TRANSACTION

    QUESTION: Our affiliate in Canada sold an item to another company in Canada.  They need to buy this item from us in the USA. Their client in  Canada cannot take the product, for it is too large and needs to be shipped to a location in the USA , their sister company.  This is an […]

  • MEUses and MEUsers

    QUESTION: I plan on shipping an item enumerated in the CCL to a Military End-User (Coast Guard- not in China, Russia, or Venezuela). Based on the reasons for control for the ECCN and the country of ultimate destination, a license would not be required. However, because of the update to the definitions of Military End-User/Users, […]

  • CTPAT Supplier Questionnaires

    QUESTION: For members that are part of the CTPAT program (importer).                                                                                                        When you send out a supply chain security questionnaire to your supplier base and the supplier answers “no” to some questions, how do you handle these types of responses?  For example, do you: Accept the answer as is Respond and ask for explanations.  Once […]

  • Small Company Auditing

    QUESTION: We’re a small company and I am the only person dedicated to our export control program. To comply with the annual audit requirement, what best practices are there for small companies to perform EC/ITAR program audits? Is it acceptable for me to perform the audit, or should it be a third party? %%%%%%%%%% ANSWERS: […]