QUESTION: I’m interested on how other members handle FOB reductions and/or air freight charges when a shipment is late, and the vendor is covering the air expense. We’ve done FOB reductions for years, but am being challenged for another way to handle the air freight expense, other than reducing the FOB price. I am looking […]
QUESTION: Is a CCATS required to use ENC? How do you know if the supplier’s classification is sufficient? =========== Answers: A CCATS is not required to use ENC. You don’t know if the supplier’s classification is correct, that is why we never rely on a supplier’s classification. ============ No, a CCATS is not always required. […]
QUESTION: Under 19 U.S. Code § 1592(c)(4) and 19 C.F.R. § 162.74(c), CBP has the discretionary power to extend the number of days when an importer must tender duties, taxes, and fees as it relates to perfecting a prior disclosure. Has anyone from the membership successfully argued to get extensions for 6 months or for a […]
QUESTION: We manufacture a product under HTS # 3907.10.0000. I am trying to determine if our materials apply to AALA requirement. I am further trying to educate myself on AALA. I have been directed to the following websites with no luck on the objective. https://www.nhtsa.gov/part-583-american-automobile-labeling-act-reports & the Cargroup.org Can anyone assist with the above? =========== […]
QUESTION: I work for a company that is foreign owned. We have manufacturing sites in several countries. The instruments we manufacture have to be “globally” classified with an HTS number. The instruments we manufacture are not “specifically” named in the HTS headings. We arrive at our classification determination based on the function of the instrument. […]
QUESTION: Please help to resolve this situation. The foreign shipper sent two importer’s cargo in one container but declared only one importer and one MOBL. Now when it arrived and cleared customs we were notified that shipment belongs to two different people. Can we file a Post Summary correction and how? How can we present […]
QUESTION: We are a US based importer/exporter of manufactured goods. We are working on a screening process for banks that our customers use to send money from/that we send money to. We receive a list of bank transactions that include bank names & addresses. However, many times only the main branch or corporate address for […]
QUESTION: We are a U.S. based company, our goods are manufactured in the U.S. with ECCN 3B992. We perform intercompany sales to our German affiliated company and they classify the same items as 3B002. Should our German counterpart follow the U.S. classification which in turn would be NOCLASS or can they override the classification since […]
QUESTION: Hello, our company is not ITAR registered and we are in the software business, we also provide consulting services regarding our products worldwide. Sometimes consulting customers can be defense companies. My question is about the definition of “Defense Services” under ITAR, it says “furnishing of assistance to foreign persons”, but does not say by […]
QUESTION: We sent a defense article controlled by Category XI(b) (SME) under a DSP-5 license to a government end-user several years ago. This item (in its entirety) is manufactured by my company in the United States. They let us know that they are finished with the defense article, as it’s reached the end of its […]
QUESTION: I have been seeing questions regarding a USA employee working for a USA employer and asking if they could perform “customs business” for subsidiaries, …etc. Also read regarding a USA employee working for that USA employer that is a subsidiary of a holding company in a foreign country, and that holding company is also […]
QUESTION: Can anyone direct me to more information that explains the concept of “principle use provisions”. Can you share electronic versions of the following? • T.D. 89-80, 54 Fed. Reg. 35127 (8/23/89) • E.M. Chemicals v USA 20 C.I.T. 382, 923, F. Supp. 202 (1996 Ct Intl Trade) • Group Italglass U.S.A., Inc. v. United […]
