• 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 […]

  • Security Concerns for COO China and Taiwan

    QUESTION: With the recent headlines about hacked microchips in Chinese origin hardware, one of our customers has asked us for a letter explaining how we verify the security of components sourced from China and Taiwan. This is the first request of this kind that we have received, and the customer hasn’t made this request before […]

  • UNSPC CODES

    QUESTION: Please advise if UNSPC codes are a regulatory mandatory requirement for your products. Our Sourcing department has asked Trade Compliance to take over the responsibility of assigning this code in our company. I am aware of the UNSPC code but,  I really cannot find that it is an absolute mandatory requirement. I would be […]

  • FOREIGN JV AND IRAN

    QUESTION: I’m a US company and we’re entering the Saudi Arabian market. We will be doing so as part of a joint venture.   My CEO has asked if that JV can do business with Iran.   Can it?  What do I tell him?  Citations would be great!   ========== Answers:   Unlikely-the point of […]

  • MTB LIST QUALIFICATION

    QUESTION: We are in the process of reviewing our product database and comparing it to the MTB list. We think we have a match to the MTB product description, but as the MTB descriptions are so specific, is there a source where we can get confirmation? ========== Answers: For the MTB, the tariff code governs […]