Miscellaneous

MISCELLANEOUS

  • Baltimore Port Direct Contact Details

    QUESTION: Can someone in the membership provide the contact details for the Baltimore port director and assistant port director; name, phone and email ========== Answer: All port details and contacts  are available on cbp.gov. ==========

  • Duties on Inland cost at the origin

    QUESTION: Current scenario: The product is being bought on EXW factory door Incoterms. The shipper arranges pre-carriage to the port and then bills us for pre-carriage on the Commercial Invoice. Pre-carriage charge is listed on the Commercial Invoice as an item line: Product cost – $ Inland Freight  – $ Question: Would Inland Freight be […]

  • Letter to extend liquidation date

    QUESTION: Our US import broker indicates that requests for extension of Entry liquidation dates (due to Sec. 301 exclusion issue) cannot be filed in ACE, and that we must write to the CEE requesting extension of liquidation dates. Does anyone have a format/template for writing to the CEE requesting extension of our liquidation dates, due […]

  • Customs requirements on Unit of Measure

    QUESTION: Have you been or know of a company that has been penalized by the CBP for incorrect UOM on entry summary?  Not related to duty draw back. We are constantly seeing import shipments that shows no weight of a part. We are not provided with the packing list. So, my broker is “prorating” the […]

  • University Customs Course Content

    QUESTION: If you were teaching (or taking) a graduate level course that covered Customs.  What topics would you want to see covered?  What do you wish you had learned about trade compliance and operations in school? =========== Answers: I’ve actually put together a syllabus and curriculum on this topic. It depends on what you want […]

  • Prospective shipment

    QUESTION: In order to request a classification ruling, it must concern a “prospective” shipment. What does “prospective” mean, in that sense? I just want an official ruling on what to classify something I produce. =========== Answers: Simple: not yet imported. =========== Read 177.1(a)(1) and 177.1(a)(2)(i) and (b). Here is 177.1(a)(1) –  A “prospective” Customs transaction is one that […]

  • Global Procedures

    QUESTION: Do any team members have a Global Procedure in place to  review import and export declarations that they would be willing to share?   The challenge faced is how do we develop a Global Procedure that can be applied to all without creating a cumbersome process for the larger locations. Additionally, interested in where you place the […]

  • Guantanamo Bay Military Base Cuba-OFAC License Exception

    QUESTION: We are being asked to ship EAR99 equipment items to the U.S Military Base in Guantanamo Bay, Cuba I have found the BIS License Exception CFR 740.11 for U.S Govt Agencies (GOV) but after checking OFAC website and 31 CFR 515 Cuban Assets Control Regulations cannot find any evidence of an OFAC License exception […]

  • Forced Labor

    QUESTION: Hi all. Curious how the members ensure they do not have forced labor in their supply chain, and how far they go to do so. Other than getting a confirmation with signature on a C-TPAT questionnaire , and having occasional surprise visits to the factories, is there anything else we should be doing? How […]

  • Foreign-owned facility,51% US ownership

    QUESTION: We own a joint venture in a non-US country at 51%; the remaining 49% is a registered resident company that has a parent that is also registered as a corporation in the non-US country.  Our collective JV company is 100% registered in the foreign country as a unique entity with the aforementioned ownership split. […]

  • Record retention on a prior disclosure

    QUESTION: We just had a resolution on a prior disclosure, but I am having trouble determining how long I need to keep the documents involved in the disclosure. Is it the typically 5 years, so 5 years from today? Or do we need to keep them indefinitely? =========== Answer: 19 CFR 163.4(a) says, “Except as […]

  • ITN not annotated on the BL

    QUESTION: My company exports agricultural fertilizer to Europe and South America via vessel.  Either we charter the vessel or the customer charters the vessel. In this case the customer chartered the vessel. Because they are a foreign customer from Switzerland we were the USPPI so we filed the EEI. We allowed them to cut their […]