Miscellaneous

MISCELLANEOUS

  • Inter-company imports / warranty parts

    QUESTION: When we SELL internationally inter-company, we use a CBP approved transfer price markup for transaction value (and approved by  CBP equivalent in destination/import country).   But when we export WARRANTY items inter-company, we use COST (no markup / no transfer price).    Is cost acceptable to use for customs valuation  between related parties in this […]

  • 600 SERIES AND EAR99

    QUESTION: If an item is specifically named in a 600 series ECCN in a .y category, and the item is used on both military and civilian articles, and not elsewhere named in the CCL, can this item ever be EAR99 when the .y states specially designed? When, if at all, are you allowed to classify […]

  • TUNING RESTRICTED PARTY SCREENING

    QUESTION: I get an enormous amount of false positives when doing Restricted party List Screening.  My match threshold is at 95%…there is nowhere else to go but 100%, which makes me nervous.  My question is this: If I load 30,000 parties to my screening tool, I may get around a 2-4% fail rate…600-1200 potential matches.  […]

  • Freight charges in box 32 of CBP 7501

    QUESTION: When a broker does not know the freight / insurance  charges on an inbound shipment, I understand an estimate is made in box 32 relative to those charges.   If I don’t know the actual and I do not deduct those charges, am I ultimately held accountable for those estimates as entered by the broker […]

  • 7501 COUNTRY OF EXPORT

    QUESTION: I’ve seen varying answers on this website concerning how to determine the country of export on a CBP 7501. I would like to see a clear response on how to make this determination. If I have a supplier in France that sells material to me and the place of receipt of the goods showing […]

  • EEI BOX 4B

    QUESTION: On the EEI, Box 4a, is the Ultimate Consignee the Notify Party that appears on the OBL & 4b the Intermediate Consignee the Sold to Party that appears on the commercial invoice? In a recent audit it was pointed out that we have not been completing 4b. It was noted that although this was […]

  • TUNING RESTRICTED PARTY SCREENING

    QUESTION: I get an enormous amount of false positives when doing Restricted party List Screening.  My match threshold is at 95%…there is nowhere else to go but 100%, which makes me nervous.  My question is this: If I load 30,000 parties to my screening tool, I may get around a 2-4% fail rate…600-1200 potential matches.  […]

  • USML VS CCL FOR KC-46

    QUESTION: The KC-46 is in 9A610, Military Aircraft and Related Commodities, Other Than Those Enumerated in 9A991.a., correct?9A610.y speaks to specific parts, components, accessories and attachments specially designed for a commodity subject to control in this entry, ECCN 9A619, or for a defense article in USML categories VIII or XIX and not elsewhere specified in […]

  • Verification of the authorized use of Customhouse brokers

    QUESTION: Has anyone ever received an inquiry like this from a CBP Regulatory Audit & Agency Advisory Services Office of Trade? Started with a phone call from an Assistant Field Director asking about if we use ABC broker and a specific Entry number was provided.  Assistant Director said they were investigating the ABC Broker. I […]

  • SEC 889(a)1)(A) COMPLIANCE

    QUESTION: Customers are sending notice our company is to be compliant with Section 889(a)(1)(A) and will be asked to certify such compliance. Question: Should our company be surveying our Suppliers for the same compliance? =========== Answers: We do not sign this type of certification unless we have documentation on file from our supplier to validate they […]

  • IMPORTING W/O MILL CERTIFICATE

    QUESTION: We are a manufacturing company importing a carbon steel item that requires a steel mill certificate and is also eligible for Anti-Dumping Duty (ADD) upon import to the USA.  Our supplier has told us only the country of origin but refuses to impart to us the required manufacturer’s name and address.  What is the […]

  • RECON LINE REJECTED DUE TO PROTEST

    QUESTION: For those that participate in Customs reconciliation program, have you had any issues recently with a line or lines on the entry being rejected because a protest was done? How were you able to resolve it? **************** Answers: See page 22 of the new “ACE Reconciliation External Handbook,” published August, 2020 for guidance: 2. […]