Miscellaneous

MISCELLANEOUS

  • CONSOLIDATED SCREENING LIST

    QUESTION: I was looking for the government’s Consolidated Screening List, but I’m not finding it where it once was. Was it moved? Is it unavailable during the shutdown? *************** Answers: Is it unavailable during the shutdown George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 […]

  • STOCK TRANSFER VALUATION

    QUESTION: Wondering who in the industry also uses stock transport orders (STO) and how do you deal with payment? We issue a PO to transport goods from one foreign plant(which we own) to our US plant and there is no record of a financial payment on this movement. How do I conduct a 3 or […]

  • US Co. JV in Saudi Arabia

    QUESTION: I work for a US Company and we are negotiating our first JV in Saudi Arabia. I’ve gotten management to agree to invite me, Trade Compliance Manager, into the room for the discussions. So, what do I need to know? Big picture stuff I need to keep in mind? Iran. Anti-boycott. But what else? […]

  • USING STA EXCEPTION

    QUESTION: We have a component manufactured in the USA that falls under ECCN: 0A987.g and requires a Commerce Dept license (Reason for Control FC1) This item is shipped from USA to Canada to be incorporated into a larger assembly. During the government shutdown, is utilizing the STA Exception a possibility? Or is it disallowed because […]

  • Revised CF5106

    QUESTION: I was recently made aware of the revised form set to be implemented in early 2019, depending on when the government is open for business again. Section 3 will present challenges for my group companies. I’d love to hear how other companies plan to address internally. ***************** Answers: Not the best solution, but I […]

  • SoCAL USE OF TIB FOR SEC. 232 AVOIDANCE

    QUESTION: I’m looking for input from the SoCal membership. Operations in LA & SD claim that “everyone” is using TIBs to import material into the US for processing and re-export to Mexico, avoiding payment of 232 tariffs. I find this hard to believe understanding what I do about TIBs. Any insight on this topic from […]

  • Are Registration Documents Dutiable?

    QUESTION: Are registration documents considered dutiable? For example, Company A (U.S. importer) pays company B (manufacturer located outside the U.S.) for registration documents that are required in order to sell the goods in various markets including the U.S. These documents are not required to produce the finished good(s) that are being imported into the U.S., […]

  • Maintaining Restricted Party Screening Records

    QUESTION: I am looking for input on how long members are maintaining an audit trail of Restricted Party Screening as it pertains to automated solutions doing the screening. Currently all of our partners are screened daily and the results are logged. As you can imagine now that we have been in the system for a […]

  • Auditing consignee-designated forwarders

    QUESTION: We are auditing the AES filings made by our customers’ designated forwarders and finding errors, in some case repeated errors by the same forwarder.  We provide a detailed SLI with each shipment but they are filing incorrect HTS and/or values.  In some cases it is extremely hard to get them to correct the filings.  […]

  • Miscellaneous Tariff Bill Act

    QUESTION: We are researching our products to determine if any of our products qualify for the Miscellaneous Tariff Bill Act. We did find some lighting fixtures that we could possibly claim MTB on. Our manufacturer stated that our product meets each specification noted in the MTB Act, but I wanted to know if anyone knew […]

  • Anodizing

    QUESTION: Would anodization of a fully formed stainless steel part be something that US Customs would consider a substantial transformation?  Part is made in Country A and exported to country B where it is anodized?  Would Country B be the CoO? ANSWERS: Substantial transformation according to the U.S. Court of International Trade “occurs when a product […]

  • MADE IN USA REG CITATION

    QUESTION: I know there have been multiple Q&A’s / discussions regarding FTC requirements for “Made in USA” claims – both unqualified and qualified statements.  But…  is there an actual regulatory citation that documents those specific requirements?  I am aware of the policy statements on the FTC website.  But, am challenged to find any actual regulatory […]