QUESTION: U.S.-based Company X is producing a product with an international manufacturing supply chain. In the manufacture, one step is done in Europe by Manufacturer 1. Manufacturer 1 exports the material to Manufacturer 2 in the U.S. Company X acts as the IOR. Manufacturer 2 performs an additional manufacturing step. This material is then exported […]
QUESTION: I have some cloud analytics services I would like to sell to Huawei. I am a US company. Can I even call Huawei? =========== Answer: First you need to understand if what you are selling is subject to the EAR. Next you need to read the Foreign Direct Product Rule to determine if your […]
QUESTION: If our company (Company 1) purchased another company (Company 2) that still has its own IOR number, can our company clear for Company 2 even though we do not have a sales agreement with Company 2? Company 2 is considered a to be a division of our company. =========== Answers: You cannot transact customs […]
QUESTION: We have several customers that do not want the COO listed on the customs documents we provide for export. They do however require a certificate of origin that would include multiple countries of origin. It is my understanding all invoicing should have country of origin listed for each part purchased regardless of the country it is […]
QUESTION: Does anyone have any experience with the process to update a statistical note to the HTS? =========== Answer: It depends on what you want to do, but you would start with a submission or request to the appropriate Tariff Affairs Branch of the U.S. International Trade Commission (https://www.usitc.gov/offices/tata) explaining why a modification of the […]
QUESTION: I am wondering whether we need to look into DDTC registration. Here’s our potential scenario: We are not developing a product to sell into the defense industry, our product is strictly COTS (Commercially- available off the shelf). Our partner we may work with is asking us to sign an attestation form and access a […]
QUESTION: We use a 3rd party supplier in the US to ship internal orders to our international locations. On the Pro Forma, they indicate a US HTS Number, yet shouldn’t it be the Schedule B? Also, we are often contacted by the broker to further provide EU HS codes for our EU locations. Could we […]
QUESTION: Where would the most likely classification be for plastic components that are sold to a company that will use these components to assemble into a drone killing drone UAV product. These plastic parts are used for the exterior assembly of the drone, but the parts do not have any technology to aid the drone […]
QUESTION: The drawing from my customer states that the parts and components I am selling to them are controlled by the CCL. Is that sufficient to classify in the CCL given the fact that my customer is a renowned manufacturer of ITAR products and has classified the items on the drawings they provided? My parts […]
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: This is usually associated with Defense Contractors and is a requirements of defense contractor acquisition agreements. So, if you […]
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 […]
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 […]
