QUESTION: Looking for clarification as to whether our broker was correct in claiming Special K (duty free) provision on Chapter 29 HTS without the CAS# or compound name being listed on the Chemical or Pharmaceutical Appendix. Also, looking for confirmation that according to General Statistical Notes Section 3(c)(iv) goods eligible for Special K provision are […]
QUESTION: The Importer I work for was under CBP audit at the time I was hired. The audit had been ongoing for a couple of years and they had a prior audit a couple of years before that. We have two prior disclosures out for valuation, classification and ADD/CVD. Our counsel (CBP Attorney and the […]
QUESTION: I just got done reading attachment A to customs directive 3550-055 regarding constructing MID codes for US imports. It references constructing the code a for a manufacturer or SHIPPER. My question is: is one to use the SELLER name/address or the SHIPPER name/address? Example: Seller is ALWAYS ABC Co 123 Main St Berlin Germany. […]
QUESTION: I am preparing a compliance audit/ risk assessment for my facility in Mexico. In addition to topics such as classification, valuation, etc., what questions should I ask specifically for IMMEX compliance? ========== Answers: Valuation method declared upon import and upon export usually the raw material imported is under consigment so no direct sale, but […]
QUESTION: I know this is a broad question, but when do members use outside counsel for trade compliance matters? (Some areas that come to mind include expertise lacking in-house, experience dealing with the government, benchmarking to others in your industry, or more resources/bandwidth). Thanks! ========== Answers: Really, this depends on how far your internal expertise […]
QUESTION: My company has a corporate EIN and several divisions with their own EIN’s. Each division’s shipments have been imported under the corporate name and EIN. Is that OK? If not, please explain why not. Now we want to add suffixes to the corporate EIN so we can distinguish each division’s data when we run […]
QUESTION: Can anyone tell me the specific German/EU customs code citations for recordkeeping and the types of records that need to be kept for German Customs imports? For example, i the US, recordkeeping requirements are spelled out in 19 CFR PArt 163 and Appendix (a)(1)(A) List. ANSWERS: https://www.gesetze-im-internet.de/hgb/__257.html
QUESTION: I’ve read that in the 98 Chapters of the US HTS there are 5,000 headings and subheadings. Does anyone know, approximately, how many 10 digit US HS Codes there are? %%%%%%%%%% ANSWERS: 11k You can download the excel @ https://hts.usitc.gov/export %%%%%%%%%% Based on my most recent extract (this includes the 8 digit complete codes […]
QUESTION: In screening for restricted parties in the sanctions realm, we know that it is necessary to look not only whether the transaction entity itself is restricted, but whether it is 50% or more owned by one or more restricted parties. That is, “ownership” must be determined? Why do I sometimes see people refer to […]
QUESTION: We import a plastic sheathing from China with a duty rate of 5.3% ad valorem and 301 tariff of 25%. We are looking to file a MTB petition for a duty reduction as the quantity we import is quite high but will not be over the $500,000 loss of revenue cap. We use the […]
QUESTION: I currently work in the automotive industry. I am the only person responsible for all international trade and compliance for our plant in Ohio. Recently we were obtained and I have been thinking about going out on my own. I already have a Bachelor’s in Business and am a Certified Classification Specialist. Besides getting […]
QUESTION: 1) What is the difference between sanction and embargo countries? 2) What is the difference on sanction/embargo countries on the BIS and OFAC list? **************** Answers: Trade sanctions target specific types of transactions, as in a prohibition to sell arms to a specific business, country, government or regime. An embargo represents a complete prohibition […]
