Miscellaneous

MISCELLANEOUS

  • 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 […]

  • Import Entry Audit Rating Scale

    QUESTION: I am in the process of updating the internal rating score that we use for our monthly import entry audits. I would like to get feedback from the group regarding the attached (hyperlink below) proposed scale. Does it seem reasonable?  Is anyone else able to share the rating they use for their internal audits? […]

  • Authorization to conduct customs business

    QUESTION: Our company has 3 divisions and each division has its own IOR and employs its own people to file Customs entries.  I am a LCB and is employed by one out of the 3 divisions.  I also supervise the other division customs team employees.  My question is whether or not I can file entries […]

  • RPS FOR SW DOWNLOADS

    QUESTION: Our company makes hardware mostly for professional audio applications. The hardware is available for purchase through the company but mostly through distributors worldwide. There is also some multimedia applications involved and, therefore, some software and firmware.  The software and firmware are classified as EAR99 – NLR, and subject to the EAR.  The software is […]

  • AUDIT BENCHMARKING

    QUESTION: We are benchmarking our internal trade compliance audit program and would appreciate any input on what companies use for audit frequency (how many years between audits) and if there are any metrics such a $ threshold and what are the annual targets for total audits completed in a year (% of sites audited, % […]

  • CBP4811

    QUESTION: I’d like to ask the membership if as IOR whether CBP4811 is actually completed and sent to CBP or is broker allowed to declare at time of entry or is Broker allowed to determine this ========== Answers: A 4811 is kind of like a limited change of address form notices, bills or refunds. Without […]

  • IMPORTING NON-NIOSH APPROVED ITEMS

    QUESTION: Anyone from ICPA membership is familiar with the process of importing non-NIOSH approved respirators and protective/surgical masks from various manufacturers in China? Is there any restrictions /requirement during the importing process? Anyone heard about “Whitelist”? What is the process to have medical device listed on Whitelist? Appreciate your comments and suggestions. ***************** Answers: Short […]