Miscellaneous

MISCELLANEOUS

  • CLAIMING MTB RETROACTIVELY

    QUESTION: We just became aware that a product we import is on the MTB temporary duty exemption list.  When did this go into effect?  If we did not claim duty free entry under Chapter 99 Heading can we claim it retroactively to the date of effect? The effective date is “on or before 12/31/2020”.  Not […]

  • Can we clear Customs

    QUESTION: I have an overseas supplier who buy material, who also supplies various other companies in the US.  This supplier has come forward and asked us to handle all the logistics for one of their other consumers.  What they are proposing is that they will be the shipper, my company would be the consignee and […]

  • EEI Filing – Include Freight and Insurance on Product Value?

    QUESTION: Our current standard practice is to include inland freight and insurance on our product value for the EEI filing.  We do this using a freight calculator by region as we typically are not totally certain of the inland freight costs at the time of the EEI filing. I am curious how many other members […]

  • Certificate of Origin Question

    QUESTION: We’ve recently started getting requests for a US certificate of origin for products going to China.  Does anyone have a suggestion for obtaining these certificates? ************ Add’l Answers: Google it, you will find various templates that you can purchase.  You can also contact your Chamber of Commerce (they used to sell paper forms which […]

  • EEI FOR DROP SHIP SCENARIO

    QUESTION: Scenario Company A (US) sells to Company B (US) Company A files EEI under its tax ID and exports products to Company C (MX), which happens to be an affiliate of Company B (US) Company A exports products to Company B’s affiliate in MX Question Is this non-compliant in accordance with U.S. Census Bureau […]

  • FOLLOWING THE ‘RULE OF ONE’

    QUESTION: If you are shipping commodities through freight forwarder shipment systems and you process shipments throughout the day, how can you tell if you are following the “Rule of One” 15CFR 30.37A? ****************** Answers: The only way to be  sure is to put in some checks and balances for any orders going out to the […]

  • GLOBAL COMPLIANCE REG. RESOURCES

    QUESTION: My company has just made the move to expanding our Trade Compliance department Global.  Previously we were only U.S., so I’m looking for resources and regulations surrounding import/export compliance in the rest-of-world markets, specifically EU and China. We are doing a total review of importer/exporter eligibility requirements, classification reviews, valuation rules in different Customs […]

  • Russian Sanctions related

    QUESTION: My question is about Russian sectorial sanctions, SDN and SSL. Do 50% rule and Secondary Sanction apply to SSL entities? =================== ANSWER: Yes and see below that pertains to Directive 4 The provision, exportation, or reexportation, directly or indirectly, of goods, services (except for financial services), or technology in support of exploration or production […]

  • Who can use a Reach Registration account when doing customs entry in EU?

    QUESTION: A Belgium chemical company importing in the EU is registered in REACH (as the only representative-OR of U.S. manufacturer) and currently takes title, imports, sells goods throughout Europe.   Due to restructuring, a new UK company is being formed and will take title, import, store, sell and transport goods throughout Europe.   The Belgium company will […]

  • Customs Audit

    QUESTION: Our  European entity just received notification from the German Customs Agency about an audit.  It will cover three years.  The notification did not mention any particular area – classification, value, origin as a focus.  The auditor requested read only access to our ERP system and wants access to the following documents and info: Last […]

  • KOREA STEEL QUOTA

    QUESTION: We are hoping the membership can provide answers to the following questions regarding the current Korean Steel Quota: Have Korean suppliers each been given a portion of the total quota or does each supplier request the amount of quota they require for each export transaction? How does the Korean government decide the quantity of […]

  • 7501 ORIGIN SCENARIO

    QUESTION: What should we advise our broker to declare for the country of origin of a mixture of food items (example below).  All I can find in the regulations is country of origin marking requirements and the proper way to declare sets on the 7501- nothing about mixed products. We have a trail mix product […]