Miscellaneous

MISCELLANEOUS

  • Licensing agreements

    QUESTION: We are wondering if anyone in the membership can provide a clear answer to a question we have about when a licensing agreement should be counted as an assist. Here is the scenario: Company A is an importer in the US and pays for a license to use Company B’s (which is also located […]

  • Origin and export compliance

    QUESTION: When filing the EEI, indicating domestic or foreign origin of goods is a required as a mandatory field per below reg: FTR 15 CFR30.6(a)(11) Domestic or foreign indicator. Indicates if the goods exported are of domestic or foreign origin. Report foreign goods as a separate line item from domestic goods even if the commodity […]

  • Proof of Use Certificate 15CFR 10.138

    QUESTION: We have to provide proof of use certificates for goods that we are legally importing duty-free under 9817.00.50 agricultural use. The imports happen multiple times during the year. We are considering how often to provide these proof of use certificates. For anyone who has done or is doing these certificates, how often do you […]

  • GEN. PROHIBITION 8 DESCRIPTION

    QUESTION: I am putting together a chart for employees explaining what the 10 General Prohibition mean to help them clear country alerts and actions that need to be taken I am having a hard time putting together the correct wording when I come to Gen Prohibition 8 Under the prohibition you cannot export or reexport […]

  • LCL DG Cargo Acceptance

    QUESTION: We have a product that is classified as UN3481- Lithium Ion Batteries Contained in Equipment and falls under Special Provision 188 (IMDG). We have not been able to get any forwarders or ocean carriers to accept this freight for LCL cargo out of China or Taiwan. Does anyone have an explanation as to why […]

  • RESTRICTED VS UNRESTRICTED ENCRYPTION

    QUESTION: Can anyone provide me a definitive answer as to what criteria the DOC uses to determine whether an encrypted part is Restricted or Unrestricted? A review of the regulations does not provide a straight forward answer to the question.  What I am looking for is that “elevator” answer you can give your boss when […]

  • NON-US COMPLIANCE RESOURCES

    QUESTION: Is it a common practice among U.S. based companies to employ a non-U.S. employee say in MX or IN to handle U.S. imports/exports/FTA qualifications? ****************** Answers: Based on past experience, a two part equation works well, the first on is having locals (non-us) resources sorting through the compliance details for each country and the […]

  • THIRD PARTY RISK ASSESSMENTS

    QUESTION: When utilizing a 3rd Party Software Management system to screen business partners; Agents, Distributors, Toll Manufacturers as such could we have your feedback and suggestions  on the criteria you may have used to determine who should be screened? ************* Answers: All customers, vendors, suppliers should be screened against restricted/prohibited party lists Outside 3rd party […]

  • SMELTER BLOCKED BY OFAC

    QUESTION: We have learned that we may have two entities (gold smelters) deep in our supply chain that were blocked by OFAC as of this past April. Although not specifically named by OFAC, these two entities appear to be captured by the sanctions because they are >50% owned by a blocked entity. This information came […]

  • Zero values in the entered value transmitted to Customs

    QUESTION: Our broker has been entering zero amounts for invoice lines with an extended amount under $1 in value.  Although ACE is allowing these zero dollar entry summary lines, I’m not sure this is acceptable to CBP.  Need some advice or guidance on this.  Thanks. ========== Answers: First you need to understand that CBP rounds […]

  • Customs broker cell phone instead of landline

    QUESTION: I am an educator-consultant and a licensed customs broker with district and national permit that I renew yearly. Don’t do any brokerage work. Just in case to provide my clients with services considered ‘customs business’ such as classification and so on. I work off my cell phone and want to cut off my land […]

  • Miscellaneous Tariff Bill – Qualification question

    QUESTION: Hello: trying to obtain more information regarding the miscellaneous tariff bill.  Is there any requirements the importer has to abide by in order to qualify for the miscellaneous tariff bill?  My understanding is if you have a product on the tariff list  your are good to utilize the 9902 HTS. Is it also true […]