Miscellaneous

MISCELLANEOUS

  • 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 […]

  • OBTAINING FILER CODE

    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 […]

  • Roles and responsibilities of procurement and trade compliance information

    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 […]

  • Question on Section 301, Assists and Transfer Pricing

    QUESTION: We ship US component parts to a related foreign supplier in China who in turn incorporates them into a finished product and exports back to us. I see an opportunity to lower our customs value and therefore avoid Section 301 duties but not sure how we claim the assist value on the item if […]

  • DUTY REFUND FOR SCRAP

    QUESTION: If we imported product from China into the US, Canada or Germany and later determined that it was defective but we did not want to return to China due to freight costs to China and the difficulty of getting correct currency exchange from the Chinese manufacturer could we scrap it in the US, Canada […]

  • SIGNATURE FOR END USER FORMS,,

    QUESTION: Currently we send our customers End User Forms that have to  filled out and signed manually. On this form we ask our customers to certify the product(s) they are purchasing will not be put to any prohibited end use or exported to an embargoed country and request the customer manually sign the form and […]

  • ANTI-BOYCOTT LANGUAGE EXAMPLE

    QUESTION: We discovered prohibited language in a L/C from our customer in Pakistan. Shipment in Israeli Flag Vessel Is Not Allowed We informed the customer this language had to be removed before we could proceed with the shipment, customer sent back a revised L/C removing the language but replacing with:         Shipment and Transhipment should […]

  • Mailing address for customs correspondence

    QUESTION: Our compliance department is not located at corporate and we would like to know if it’s possible to change the mailing address for customs correspondence to the offsite address without changing the IOR location at corporate.  I talked to our broker and they said this was not possible unless the IOR address was changed […]

  • What licensing vehicle to use in SNAP-5 TMP to in country transfer

    QUESTION: Our company sent hardware to our foreign subsidiary in for use in a trade show.  Now our foreign subsidiary would like to do an in country transfer to another company. Based on the ECCN and the BIS Part 740.9 the article sent to our foreign subsidiary qualified for the BIS TMP exception.  Since the first […]