QUESTION: From a C-TPAT and/or General Customs Compliance standpoint, would there be any compliance issue if… – one of our vendors changed from X (who used Manufacturer C) to Y, – the new vendor Y kept the same Manufacturer C and the Importer of Record kept the same Stock Keeping Unit (SKU) Number for Manufacturer C? […]
QUESTION: In talking with our project management team the discussion for best practices for screening new potential customers in the US came up. I believe best practice is screening before you even contact the company. My PM asked where an infraction could occur if the quote was presented to the customer due to insufficient screening, […]
QUESTION: Asking the membership for their assistance in specific citations that enumerate what is required .vs. what is nice to have. Commercial Invoice Packing List SED ========== Answers: For imports see 19 CFR § 141.86 ========== For Items that are controlled. New rules Effective Nov. 15, 2016 as part of the President’s Export Control Reform (ECR) […]
QUESTION: I’m fairly new to my position (as our company’s EO) and I’m not convinced the company’s process of re-importing our company’s ITAR/CCL/USML items is correct. I’m therefore attempting to ensure our regulatory ducks are in a row. We file for our own export licenses, file via ACE prior to shipping export-controlled parts/equipment, and we […]
QUESTION: Who is ultimately responsible for the arrival (ocean) port charges when the Incoterms denote the vendor is responsible for the freight to an inland destination, such as DAP Laredo TX? My understanding is that any original destination ocean port charges should be paid by the Vendor where the agreed upon Incoterms are DAP […]
QUESTION: FDA has hand sanitizers in California that have been refused entry. We need to destroy them, but are being advised that we cannot in California. Does anyone know what states allow will allow destruction of hand sanitizers? %%%%%%%%%% ANSWER: Is the FDA requiring destruction only or can you export them instead? If you are […]
QUESTION: Can anyone verify the correct UK website for their “new” HTS codes since Brexit? %%%%%%%%%% ANSWERS; We, in the US, are still using this site and our offices in England and Aberdeen advise it is the correct one to use post Brexit: https://www.trade-tariff.service.gov.uk/sections The Online Trade Tariff: Look up commodity codes, import duty, VAT […]
QUESTION: What is the difference Dangerous goods and Hazmat? For example: Shipping Li-ion batteries UN3481 PI967 II – is not considered DG. Can someone help explain why this will not be considered a DG shipment? %%%%%%%%%% ANSWERS: Technical Instructions for the Safe Transportation of Dangerous Goods by Air and the UN model regulations: “Dangerous goods are […]
QUESTION: We did a transfer pricing study for customs and it appears that we overvalued our products for import . In other words, the US parent company owes our Canadian subsidiary certain amount. The intercompany transfer was made for tax purposes but I wanted to know if we are required to inform CBP. I would […]
QUESTION: The regulations state that if the FPPI chooses to appoint a freight forwarder to facilitate the shipment, the freight forwarder must be in the United States. The question is, can the FPPI’s freight forwarder from overseas create the shipment label or does that defeat the rule about appointing a U.S. agent? =========== Answer: There’s no law […]
QUESTION: Looking for industry input if companies are screening against the US SAM list as part of your screening program? This list is the System for Award Management. It is my understanding that entities/persons on this list cannot apply or be awarded government assistance; but are not considered debarred or sanctioned from international activities. I […]
QUESTION: Company A USA transfers inventory to Company B South Korea both are related entities. Company B repairs the goods and returns the goods back to the USA. I am looking for guidelines for transfer price valuation for shipping these items to South Korea for South Korea customs purposes. ***************** Answers: Korea is a part of the […]
