Miscellaneous

MISCELLANEOUS

  • WAREHOUSING REPORTING LINES

    QUESTION: It would be interesting if ICPA members, placement firms and others could share of best practice for reporting lines of warehouse, shipping and receiving staff. Do these positions report up to Supply Chain, Logistics, Operations? ============ Answers: We don’t have a Logistics department, therefore, warehouse, shipping and receiving staff report to Operations. ============ I […]

  • INTERNAL OFAC COMPLIANCE PROGRAM

    QUESTION: I am wondering, how many companies have a formal OFAC Sanctions Compliance program document that they publish, post and train against?  I am not talking about having all the requirements  covered in one way or another (screening, training, risk assessment, etc. conducted by various teams or departments) or having a policy statement or document […]

  • FOREIGN INLAND FREIGHT

    QUESTION: We would very much appreciate the membership feedback to this situation. We are working to set standard incoterms with our non-North American supply base and have a debate if FCA Supplier’s Dock or FCA Origin Country’s Port of Export is more appropriate. (Wuxi, China vs. Shanghai POE for example) Referring to this FR as […]

  • NEW HUAWEI RESTRICTIONS

    QUESTION: I sell EAR99 items to Huawei from a non-US location, hence the FDPR G.P. 3, but these items are not directly used to make Huawei products.  What I sell are items for supporting the building within which Huawei makes products that are now controlled. Because my items are EAR99, no Huawei components are installed […]

  • Chamberized COOs

    QUESTION: My company is doing a pilot program for self-filing via AES Direct.  We are currently not set up to issue Chamberized COOs as this is currently done by our Freight Forwarders.  There are thousands of Chambers of Commerce and various online services.  My dilemma is that my company belongs to many Chambers of Commerce.   […]

  • GLOBAL TRADE MGMT SYSTEM

    QUESTION: What would you expect your Global Trade Management System do for you? =========== Answers: Restricted Party Screening that receives and sends data with my ERP system; tariff classification with the ability to create decision trees and including CROSS rulings and explanatory notes and updates my ERP system; free trade agreement qualifications; export and import […]

  • Average Cost or Standard Cost

    QUESTION: Our finance team is discussing whether it should follow the Average Cost or Standard Cost costing method.  Does this decision have an impact on the customs valuation for imported or exported product?  If so, please explain what the impact is and which costing method should be used for imported and exported product. ************** Add’l […]

  • SELF-STAMPING CHAMBER OF COMMERCE CERTS

    QUESTION: I was told that our company has a stamp from our Chamber of Commerce so that we can stamp our own export documents when requested by the customer.  Is this valid? My understanding of the Chamber stamp signified that the Chamber as a third party reviewed the documents to for completeness and certified them. […]

  • HTS classification question EU and US

    QUESTION: Looking for HTS classification assistance here- for EU and US The plan is to purchase and import material that was extracted from a plant and subsequently refined and purified. This would be classified in Chapter 13. This material has also been granted a CAS number. When searching for the CAS number for the chemical substance in the […]

  • Working With Sale on Compliance

    QUESTION: I was wondering if anyone in the membership would be willing to share how they collaborate with their sales team to ensure export control and licensing approvals are in place before an order is entered in their ERP systems. One of the major struggles I have experienced is the disconnect between Sales, Compliance, and […]

  • APPROVED FOR USE VS. IMPORTATION

    QUESTION: I have been discussing with my colleagues in Reg Affairs the difference between the phrases “approved for use in a market” and “approved for importation into a market”.  By approved for importation, I mean industry registrations (USDA, Min of Health, FDA, FCC) or special documents to accompany a shipment or specific data that needs […]

  • PRODUCING RECORDS TIMELY FASHION

    QUESTION: When the regs dictate that I must be able to produce records in a “timely” fashion, what exactly does that mean? It can’t mean immediately or instantly, right?  A few hours or a day should be adequate? *************** Answers: Great question!  There is generally a rule of reason applied here.  CBP’s recordkeeping ICP provides: […]