Miscellaneous

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: The company that I work for is researching more effective ways to track and log classification changes. Typically, once we identify a misclassified SKU, we search for similar SKUs, make corrections accordingly, and follow up with any post-entry work if necessary. The spreadsheets related to classification changes are saved within folders on our shared […]

QUESTION: We frequently ship reusable plastic trays produced in the U.S. that contain our product protected in foam compartments. The empty plastic trays return separately. How do you track the imports/exports? What verbiage does your shipper use to instruct the freight forwarder/carrier? Are there any requirements to track each individual tray (by serial number, etc.)? […]

QUESTION: This is more of a logistics issue than compliance but I am hoping someone can help me. We ship high value gold, silver and platinum shipments to and from Canada and the US. Our courier has stated they will no longer pickup any shipment valued at over 250K for the safety of their drivers. […]

QUESTION: Does anyone have an encryption questionnaire they are currently using and would like to share? I’d like to compare what we have. %%%%%%%%%% ANSWER: Hello, Attached is the ENC Questionnaire that we are using to classify encryption products. https://www.icpainc.org/wp-content/uploads/2014/10/2019-Encryption-Questionnaire-Template.pdf %%%%%%%%%% This is how we used to do it back “in the olden days”, but […]

QUESTION: I recall seeing a poll somewhere that in the last 10 years Trade Compliance has been making a move out of Supply Chain and into other departments. Looking for the membership to share how they’ve been able to get Trade Compliance OUT of Supply Chain and into Legal, Audit, Finance, etc. What arguments did […]

QUESTION: We have a routed transaction and there is a valid POA on file between the FPPI and their US forwarder. The FPPI provides authorization to their forwarder and to the USPPI that says the AES filing can be made under the USPPI’s EIN number instead of the FPPI’s. This “authorization” circumvents the need for […]

QUESTION: We hired someone for a US compliance role, US Compliance Specialist. Advised verbally that the role would “support” other import sites globally. This global support and activity was never put into the job description. This US compliance role has evolved to spending more time on the other sites in other countries. The title was […]

QUESTION: What is the benefit of using one of these zones in Jordan for importing into the US to receive duty-free treatment, if the goods still need to have 35% local value content just as they would need in any event to qualify for duty-free treatment under the the Jordan-US FTA? ========== Answer: For clarification, […]

QUESTION: Our US Customer would like to place an order with our US Company for goods that can only be produced in our GB facility (the customer is the design authority not my company). They would like us to order it from GB and have it turned over to their freight forwarder to handle the […]

QUESTION: We manufacturer an EAR99 scientific device that will be incorporated by a foreign company into a large research system to be sold to someone on the Entity List. The value of our component is <10% of the total value and is not listed on § 734.4 De minimis U.S. content exclusions. At first, I […]