Miscellaneous

MISCELLANEOUS

  • RETURNABLE CONTAINERS – DUNNAGE

    QUESTION: How do others manage returnable containers/dunnage on their invoices/manifests/entries when they are filled with parts? In recent discussions with an Import Specialist we’ve been advised that every shipment needs to show the returnable containers and an associated value under 9803.00.50/Duty Free – Plastic Containers, IIT, Instrument of International Trade. In my experience, the containers/dunnage were […]

  • Restricted party screening of foreign service vendors

    QUESTION: For those in trade compliance at global companies, you probably screen suppliers of merchandise/materials in addition to customers of your products and/or services. Do you also screen the myriad variety of service providers that you have around the world, such as, to cite a random example, vendors of cleaning services for your company-owned stores […]

  • ACH SET-UP CF 5106

    QUESTION: We are trying to set up our company on ACH (mulitple divisions) .After sending form 400 and being asked for a 5106, all has been going smooth and the PUN was finally obtained for some of our divisions. We then continued to go one EIN at a time for the next batch of divisions […]

  • DEA EXPORT JURISDICTION

    QUESTION: Does anyone know of a list that has an additional column, for the DEA regulated substance that may fall into said HTS and hence require reporting/permit? ******************** Answers: There is a list of HTS that “could” require DEA export permits or reporting; these flag in ACE when filing AES. https://www.cbp.gov/sites/default/files/assets/documents/2019-May/New%20Master%20DEA%20Drug%20Code-HTS-Schedule%20B%20Reference%20Table%2005012019.xlsx But it’s not 100% […]

  • Employee Sanctioned Party Screening for employees

    QUESTION: How does non-US multinational companies managed Sanctioned Party Screening for employees as it relates to GDPR and privacy global and local laws? Do you have US dedicated plus global policy? Or perhaps the norm is not to screen while the US becomes the exception? Do you screen US employees? Thanks for sharing and for […]

  • DECCS registration and licensing–Third parties

    QUESTION: The DECCS FAQ on the State Dept website states third parties who work with registered companies must have a unique email for each company they work for.  In other words, you cannot use your same business email for multiple clients.  What is a practical method to create all of the emails, within your business […]

  • Temporary import procedure

    QUESTION: Does anyone have a global temporary import procedure they can share? I realize it’ll have to be fairly high-level because of how different each country’s temp import regs are. %%%%%%%%%% ANSWER: Cannot share but consider the following as you put something together: 1) ATA Carnets – can be cumbersome and penalties apply if you […]

  • INTERCO WARRANTY COSTS

    QUESTION: This question is targeted to those in industries that have dealers, and distributors in foreign markets, particularly in China. We, the parent company, have related party transfers between distributing entities in foreign markets. All of our intercompany distributor agreements state that the distributor is responsible for all warranty costs incurred in the country, therefore […]

  • Bonded warehouse set up

    QUESTION: Anyone set up a bonded warehouse? Do you have a template that can be used for the application? Any other advice? %%%%%%%%%% US Customs has published an entire manual.  See https://www.cbp.gov/sites/default/files/documents/bonded_warehouse.pdf ================================================================

  • FIRST SALE INVOICING PROCESS

    QUESTION: Our company has a first sale process that requires our team in China to create the customs documentation for this program.  The program has been approved by outside counsel as well as CBP. We recently lost some staff in our China location, and the U.S. will need to take over the tasks done in […]

  • Truck bill of lading

    QUESTION: From a legal and regulatory perspective, who is responsible to create the truck bill of lading when a freight forwarder makes the transportation arrangements with their nominated trucker (carrier) to pick up from the shipper? According to 49 U.S. Code § 14706 Liability of carriers under receipts and bills of lading, under General Liability (a) 2, […]

  • Lease to buy

    QUESTION: Is it permitted to import an item on a lease agreement under an ATA Carnet and that during the lease period decide to buy the item?  Would there be any issues with penalties and fines under the ATA or would we simply just file a consumption entry  and make whatever necessary reporting for closing […]