Miscellaneous

MISCELLANEOUS

  • 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: […]

  • CUSTOMER VETTING

    QUESTION: How do other companies maintain that their 3rd party companies screen and vet their customers, suppliers and vendors properly?  In other words how far do you go with a 3rd party agent?  Do you feel it’s necessary to screen and vet an international bank that will receive wire transfers as well ?  ========== Answer: […]

  • Changing tariff codes on entries

    QUESTION: We just acquired a company that’s been using the wrong tariff code (duty free, no China tariff) for a product they were importing.  We have started to use the correct code (duty free + 25% China tariff but there was an exclusion until 12/2020). What is the recommendation for previous entries using incorrect code […]

  • Acquisitions

    QUESTION: The company I work for continues to purchase smaller businesses who operate independent of the parent company, meaning they are retaining their own Tax ID.  I’ve heard them described by leadership as stand-alone companies, we just own them. Because these new companies are owned by the parent company, I do solicit them for C-TPAT […]

  • Answers to C-TPAT Survey

    QUESTION: As promised, attached are the results from the recent C-TPAT survey. https://www.icpainc.org/wp-content/uploads/2021/02/ICPA-CTPAT-Survey.pdf

  • IMPORTER VALIDATIONS BY BROKER

    QUESTION: In regards to this proposed ruling 84 FR 40302, where Customs Brokers must verify their clients, is this an official requirement?  Our new broker is asking for our CEO’s government ID and want to make sure this is already a requirement before requesting this from our CEO.  I’d like to include the CFR citation […]

  • TRIENNIAL REPORT FILING

    QUESTION: I found out just a couple of weeks ago that my Broker’s License was issued as of January 2021. To give an idea, all I have so far is my license number and a courtesy notice from the port I applied at that the license was approved. Would I still need to file a […]

  • Volume Discounts and Penalties

    QUESTION: My company is looking to enter an agreement with a foreign vendor where we would pay a discounted value post purchasing a minimum agreed volume of product, but if we do not purchase the minimum agreed volume of product, we will pay penalty.  My thinking is that we would use invoice transaction value as […]

  • Custom Brokerage Exam Prep (April 2019 Exam Answer Explanation)

    QUESTION: I am preparing for the 2021 April Customs Brokerage Exam and am currently taking previous exam as practice.  Question #47, from the April 2019 Exam, in the Practical Exercise section has me lost.  A commercial invoice is given to answer 5 questions, with no other instruction or information.  Follow the link April 2019 Exam […]

  • Certificate of Origin

    QUESTION: Scenario: My organization is a chemical manufacture and recently imported US product (USMCA Inventory) to a leased facility as a related transaction. From this facility the inventory is then sold as a domestic transaction within Canada. We cannot guarantee our product is not combined with non-originating inventory at facility. The Canadian customer is now […]

  • PRODUCT STANDARD DETERMINATIONS (UL, CE, NOM, etc.)

    QUESTION: Can anyone share with me where the role of ensuring a product meets UL, CE, MX NOM or any other country specific OGA requirement for safety or standards (Cert of Conformity) lies in your company? I realize these things impact the ability of a company to import into a country but to me these […]