Miscellaneous

MISCELLANEOUS

  • FMS and Commercial Invoice

    Question: In the case of an FMS sale, is the US manufacturer of the defense article required to issue the export commercial invoice or is the invoice issued by the U.S. government. I have a case where a client, the U.S. manufacturer of the defense article is being asked to issue the commercial invoice (request […]

  • Acronyms

    Question: Good morning – can someone tell me where I can find a list of acronyms and the meanings used for Import/Export and Supply Chain ?  Thanks so much, Answer 1: This may be helpful.  https://www.thompsoncoburn.com/docs/default-source/publication-documents/trade-compliance-handbook1-29-20163c302326dda26f05acb8ff0000ba5cc9.pdf?sfvrsn=1e924cea_31  Answered by: Robert Shapiro – rshapiro@thompsoncoburn.comTitle: Partner, Company: Thompson Coburn LLP

  • NON-US PERSONS PROVIDING HTS SERVICES

    QUESTION: From this week’s Federal Register Notice, “CBP has clarified in Headquarters ruling H045695 (October 15, 2010) that classification at the six digit HTSUS level does not constitute customs business. In addition, classification at a level lower than six digits, such as the four-digit HTSUS level, is not considered customs business either. Even though CBP […]

  • UFLPA

    QUESTION: What happened to those Poly silica shipment that got stop due to UFLPA?  If they were released, what documentation is needed to release them? *************** Answers: Information on detained shipments under WROs or UFLPA is not being formally released by CBP, although informationally there is no polysilicon being released for entry if the importer […]

  • Documents with carrier

    QUESTION: It’s been some time since I’ve been involved in preparing documentation for an export shipment.  With that said, many years ago we sent all invoices and documentation electronically to a customer’s broker instead of with the truck carrier.   Upon joining my newest company, I’ve been told all documents are sent WITH the physical shipment […]

  • Definition of Agent in intermediate consignee 15 CFR 30.6(b)(2)

    QUESTION: Can anyone tell me the definition of “agent” in the context of 15 CFR § 30.6(b)(2) Intermediate Consignee?  Would an agent be a buying or selling agent, distributor, export agent?  What is the role of an agent? 15 CFR § 30.6(b)(2) Intermediate Consignee – The name and address of the intermediate consignee (if any) shall be reported. The intermediate […]

  • NON-US PERSONS PROVIDING HTS SERVICES

    QUESTION: From this week’s Federal Register Notice, “CBP has clarified in Headquarters ruling H045695 (October 15, 2010) that classification at the six digit HTSUS level does not constitute customs business. In addition, classification at a level lower than six digits, such as the four-digit HTSUS level, is not considered customs business either. Even though CBP […]

  • CUSTOMS ENTRY AUDIT CHECKLIST

    QUESTION: Our company is now bringing customs compliance in-house, and we are aware that the rule of thumb is to audit approx. 10 – 12% of our entries. I would like to set up a good cadence for monthly audits, but can’t seem to find a good template/checklist. Would any members possibly have an audit […]

  • 5106 Address Change

    We recently sold off several of our U.S. entities. I asked the Customs broker (the same broker will still be used) to transmit a 5106 change to the new address. All but one went through. The one that did not go through came back with a message that the importer# (the EIN) is frozen and […]

  • SUBJECT TO US TARIFFS

    Players: Company A – USA            Seller Company B – China         Vendor producing product for Company A Company C – Canada      Buyer, IOR Scenario: A takes the order from C,  product is made by B Product is shipped directly from B to C                 The product does not cross US border. Question: Who pays Canadian Tariff; […]

  • CUSTOMS BILLS – PROTEST PENDING

    We have a situation where Customs has issued 9 bills to our company for an exclusion, they claim had expired on 5/31/22.  However, the exclusion was extended through 11/30/22.  We have sent the FR to our CEE proving the exclusion was extended. Of course, now that we have received the bills this means the entries […]

  • Filing Updates TMP to Permanent License

    QUESTION: Seeking guidance on updating AES Filings related to a change in export authorization. Example is the transfer of articles originally exported under TMP to a permanent export with an approved BIS License. How does industry close the TMP in AES and transfer those items to a permanent export? Thank you in advance. *************** Answers: […]