Miscellaneous

MISCELLANEOUS

  • TRADE CONTROLS

    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 […]

  • Exchange rate for US Imports declaration

    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 […]

  • DROP SHIPMENT BEST PRACTICES

    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 […]

  • SIMPLE DEFINITION FOR TECH DATA

    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 […]

  • Non-EU company no longer can be named exporter on declaration

    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, […]

  • Operating principles

    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? %%%%%%%%%% […]

  • SCREENING FOR UNRELATED SELLERS

    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 […]

  • PETITIONING FOR MTB

    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 […]

  • MID RULES

    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 […]

  • Miscellaneous Trade Bill Details

    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 […]

  • CHILE CUSTOMS PROCESS

    QUESTION: Does anyone know how exactly is the customs clearance process in Chile, South America ?? =========== Answer: Can you are more specific on what about the process it is that you need to know and what the product is that you would be trying to clear? Also, below is the link to the Chilean […]

  • FORMULA FOR LOWEST COST MANUFACTURING COUNTRY

    QUESTION: Does anyone have a formula for computing the lowest cost manufacturing location (by country) of a finished good that takes duty (both MFN and China tariffs), freight, and country of origin into account? This formula would have take into account the duties paid versus the “all in” transportation costs, and if one component changes, […]