QUESTION: With the Hong Kong Autonomy Act being signed into law, will the Section 301 tariffs be applied to imports made in HK now? %%%%%%%%%% ANSWERS: https://www.whitehouse.gov/presidential-actions/presidents-executive-order-hong-kong-normalization/ %%%%%%%%%% Yes. ================================================================
QUESTION: With the onset of Hong Kong now being treated as China, has there been anything stated about a change to the two digit country code to be utilized for imports and exports. Are we still to use HK or should it now be CN? %%%%%%%%%% ANSWER: My understanding is that you will report CN. […]
QUESTION: We are looking for ways to mitigate tariffs besides the use of exclusions on products for building infrastructure. Does anyone know if there is a provision or program for products used in building infrastructure that allows for a reduction in tariffs? ******************* Answers: Tariff reducing provisions and programs? There are numerous. Free Trade Agreements (FTAs); […]
QUESTION: What are the tools/mechanisms that OFAC has at its disposal to discover a potential violation of a US foreign owned company conducting Business with a 50% sanctioned ownership company? Even when the US company does daily screening against the 50% sanction lists that are out there, those lists may not be complete, and […]
QUESTION: The 32 FAQ’s regarding Venezuela do not directly answer these questions. Seeking help from the members: Regarding the recent changes in export law to Venezuela, what is the likely correct answer to the following: Product “A” is not military at all, no dual use, completely civilian, EAR99, but Product “A” [a fully automated pallet […]
QUESTION: 3 scenarios. Facts as follows: US Company “A” sells to Europe company “B”. No OFAC sanctions in place on company “B” AND Company “B” is not owned in aggregate of 50% or more by OFAC sanctioned entities. Company “B” places a PO to company “A” and in the PO instructs company “A” to ship […]
QUESTION: Our US company will be leasing manufacturing equipment to a manufacturer in Thailand. The equipment will be used to manufacture a product for sale within Thailand and to other countries. The manufactured product will NOT be exported to the US. Our US company will receive a royalty off the sales of this Thai manufacturer. […]
QUESTION: Can someone confirm that if the export consist of only EAR99 and NLR, the export is exempt from the EEI filing change on 6/29/20? %%%%%%%%%% ANSWERS: Below is a reply we received directly from BIS’ Regulatory Policy Division: QUOTE Please review the guidance that BIS has provided on its website at https://bis.doc.gov/index.php/all-articles/2-uncategorized/1686-revisions-to-eei-filing-requirements-pursuant-to-revisions-to-section-744-21-china-russia-venezuela-military-end-use-end-user-rule. Per the […]
QUESTION: With the new EEI filing requirement for all shipments to CN, VE and RU regardless of value, I’d like to know if anyone in the membership has knowledge that the main small pack express carriers have had their shipping software updated to accommodate the new export filing requirement where it will raise a flag […]
QUESTION: Can a foreign entity apply using BIS Snap-R website for a US export or re-export license ? where in many cases, BIS require attach drawing or technical specification of controlled items, can be considerate a deemed export? =========== Answers: Anyone can submit the application, but they must be in the United States at the time a […]
QUESTION: If an HTS specifically says “put up in forms or packings for retail sale” can you only use that HTS when it will be sold at retail? Or is it more referring to the format? For example, if our company is importing an item for our own use but it’s the same packaging format […]
QUESTION: What are the ramifications if a company has a Freight Forwarder that is exporting goods for a company but the USPPI ID does not equal the USPPI name and/or the address? I’m would assume these are all routed transactions but they are not all flagged that way in the AES-202 report. %%%%%%%%%% ANSWERS: Unclear […]
