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? […]
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 […]
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 […]
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 […]
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., […]
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 […]
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. […]
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 […]
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 […]
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 […]
QUESTION: Does anyone have any information they can provide about the process for filing for a filer code so they are able to self-file customs entries? The CBP website is very vague and only states to send a request to the port director with name and address, tax id and filer role. Is there more […]
QUESTION: Can others share how they, as trade compliance professionals, handle the process of obtaining import data (ECCN, HS Code, Origin, FTA COO) from vendors their companies purchase product from which their company will import or eventually export? For OEM product, does procurement have any responsibility for getting the info from vendors that is needed […]
