QUESTION: Hi everyone. We have a question about the potential importation / shipping of LED flashlights. Various products fall under the following HTS Codes: 8513.10.2000 – Flashlights 8513.10.4000 – Flashlights: Other 8513.90.2000 – Of Flashlights There is a question regarding transportation / compliance requirements if these are shipped with or without batteries (alkaline is the […]
QUESTION: I just got done review the OFAC N Korea sanctions. It appears that they do NOT apply to foreign subsidiaries/majority owned foreign joint ventures of US companies (like several other sanctions programs). 510.326 definition of US Person does not include foreign subs. So it appears that foreign subs of US companies are not subject […]
QUESTION: We are a U.S. company with 5 divisions working on our document that communicates information on sanctions, screening and antiboycott Want to ask the membership: • How you communicate this information and requirements? Via a corporate policy? Via corporate guidelines? Other? • How long such a communication is? • How updates are communicated and […]
QUESTION: We are setting up a new solution to file imports entry and entry summary with CBP and have a question on exchange rates to be consumed. Our supplier (exporter) provides invoices in non-USD currency and hence we need to bring in the exchange rates from cbp. However, the cbp site has exchange rates in […]
QUESTION: I am seeking any best practices the membership may have regarding drop shipments from China (or any foreign country) shipping direct to customers in the US. We are the importer of record (IOR) and would like to declare the (lower) transaction value between us and supplier in the foreign country upon import into the […]
QUESTION: Can anyone share a good definition of technical data that would cover both EAR and ITAR? We are trying to educate a broad range of non-trade stakeholders how to identify when they are dealing with technology/technical data, as part of export compliance awareness training campaign. We want to make sure that people understand both […]
QUESTION: We are a US only entity but have registered and obtained an EORI# (NL) and a VAT Registration number (NL). Dutch Customs published a news message stating that as of Dec 1, 2019, non-EU companies can no longer be the ‘exporter’ (box 2 of the export declaration) Aside from setting up a EU company, […]
QUESTION: I was wondering if you can share briefly what is your internal operating principles of collaboration between Export/Trade compliance, in-house legal and outside counsel. Do you (as a export compliance person) communicate directly with outside counsel? What role in-house legal play in compliance? Do you find it challenging to build partnership with legal? %%%%%%%%%% […]
QUESTION: We are a US company who recently sold all of our foreign assets (UK, RU, CN, IN, EU) to a German company. Without consulting the Trade Department, IT decided that Trade Compliance would continue to screen the sales orders between our previous held asset locations and their buyers. What I mean is an order […]
QUESTION: Has anybody in the membership petitioned for MTB (Miscellaneous Tariff Bill) and if so, could share any tips on the best way to approach the application? Would you be able to share the name of the company that assisted you with the process? Did you file on SKU level or HTS level? Have you […]
QUESTION: In regards to manufacture id rules, I have some questions. no city division for this location in Vietnam – do we skip this part? shipper address is in MARSHALL ISLANDS but product is produced in China. shipper address is in Hong Kong but product is produced in China. 2 different factories located in China […]
QUESTION: The high majority of our imported products are duty-free. Of course the current tariffs have caused costs to increase. I understand that the MTB does not provide relief for items that are subject to tariffs, or other trade actions, such as anti-dumping and countervailing. For these reasons, I have not paid much attention to […]
