QUESTION: Does anyone have any feedback in the membership as it relates to non-US employees managing imports into the U.S.? Is there concern over allowing them to access the data that will be transmitted to US customs? Is there a section in the regulations that addresses this matter? ************* Answers: It’s perfectly fine. There is […]
QUESTION: Regarding tariffs and duties: Lithium batteries and cells imported from China from our a wholly owned subsidiary, are produced, in part, using materials that are provided from our plant in the USA. The materials that are shipped from our USA plant to China are made and sourced in the USA. I don’t have an […]
QUESTION: I am looking for data regarding how companies structure their organization for personnel that are responsible for HS classification determination. I am particularly interested in large companies classifying chemical or other commodities that require specialized technical skills (for example: a chemist) for classification. Is it centralized under one department? Is it centralized under one […]
QUESTION: Has anyone from the membership successfully argued and eliminated the duty/fee liability where goods were seized because of an OGA requirement not met and not entered into U.S. commerce as a result? If so, what regulation/guidance was relied on in presenting to CBP. Thank you for your time in advance! **************** Answers: Not sure […]
QUESTION: What is the benefit to have a CBP national account manager? What size of company is good to have one. We are in the CTPAT program, we have a custom assigned agent look after our CTPAT, is this person also our national account manager. What are some disadvantages to have CBP national account manager? […]
QUESTION: We are a pharmaceutical company recently expanded. We hope to implement a single global standard on determining country of origin. We do not take advantage of FTA’s as they do not financially benefit us. Any thoughts on the possibility of implementing one global process applicable in more than 50 countries? Would it be advisable […]
QUESTION: Is anyone else in the steel industry or trade community having a problem when filling out the exclusion request with the excel cell rounding their entered data? Example- in the cell for minimum thickness, I type 3.68mm but the exclusion request application rounds it to 4mm automatically. This is not what I typed but […]
QUESTION: Cast of Characters • Company DE • Company KR • Company U.S. • Forwarder DE • Forwarder U.S. • Broker U.S. • Pallet A-U.S. • Pallet B-U.S. • Pallet C-KR Scene (Problem) • Company DE exported Pallets A-U.S. and Pallet C-KR, to U.S. (EXW) • Company DE exported Pallet B-U.S. to KR (EXW) Notes […]
QUESTION: Is it compliant under the OFAC sanctions for a U.S. company, to sell a U.S. product to CITGO for delivery to CITGO in the U.S.? %%%%%%%%%%% ANSWER At the moment, the US has exempted Citgo from its sanctions until July 27. Still, I would recommend flagging as a high-risk customer already now, as these […]
QUESTION: Who does the BAA compliance analysis at your company? I feel like it should be procurement or supply chain. I’m a trade compliance manager and I’m being asked to do it. I feel like it shouldn’t be me. Am I wrong? ********************* Answers: From a procurement standpoint there really is not much for either […]
QUESTION: Does an importer need to apply for a ruling to see if their products qualify under the Nairobi provision, or would it be reasonable to reference an existing ruling for a “like” commodity for justification to use this provision? %%%%%%%%%% ANSWER: To get a better idea of the nuances of the qualification requirements, take […]
QUESTION: We have software that we want to make available for public download from our website in the USA. This would be a trial version of the software that expires after a period of time. If the user wants to continue using the software, they would have to purchase a downloadable software key. To download […]
