QUESTION: Facts Company A in US purchases goods from Company B in US Goods are manufactured at Company B in FR Once manufactured, goods need to end up at Company C in DE to incorporate into prototypes for Company A in US What we want to do is ship directly from Company B in FR […]
QUESTION: Has anyone from the membership gained licensing approval after a DSP-5 denial where the the Department of State determined that foreign consignee/end-user was an unreliable recipient of U.S.-orig in defense articles, defense services and technical data? If so, what actions were taken to rebut/improve the stance to get the approval in the follow-up license […]
QUESTION: My employer has a 50/50 JV with another company. Under 19 CFR §111.1 there is an exception to the “customs business” requirements called “corporate compliance activities” which allows related business entities to perform import activities to each other. The exception has ownership threshold of more than a 50 percent. In Ruling HQ 116220 CBP […]
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 […]
QUESTION: It is my understanding that with the MTB program you are only permitted to get relief with product you petitioned for. Yet on the Excel version of the petitioners and the product there is a column that says ” Relief sought available to any importer” . There are many products marked yes. Is this […]
QUESTION: Has anyone seen an increase in the Census requests for pricing information? We have been participating for years, 1 request a month like clockwork, with no deadline, and 4 or 5 parts. I am now receiving 2 or 3 a week with 48 hour deadlines. I don’t know if it’s a new Census […]
QUESTION: The company that I work for is researching more effective ways to track and log classification changes. Typically, once we identify a misclassified SKU, we search for similar SKUs, make corrections accordingly, and follow up with any post-entry work if necessary. The spreadsheets related to classification changes are saved within folders on our shared […]
QUESTION: Is anyone aware of any problems importing charcoal? ********** Answers: Charcoal is regulated under the Lacey Act (see hyperlink ). Make sure your PPQ 505 forms are in order and you can substantiate (objective documentation) the country of harvest, genus/species, and proper reporting quantities. http://www.icpainc.org/wp-content/uploads/2014/10/Lacey-Act-Implementation-Schedule-102913.pdf ************ Don’t know of any Customs/OGA issues per se….but […]
Question: We have an evaluation board (manufactured in CN) shipping to our CM in UK to have the customer specific software loaded onto the board The evaluation board (EVB – with IC / FPGA) – shipping from CN to the US would have COA is CN? The same EVB, now shipped to the UK to […]
QUESTION: I would like to understand what the industry’s take is on having a freight forwarder file the EEI in a routed export transaction that is not actually the FPPI’s freight forwarder but rather ours, the USPPI’s? The situation that I have is the freight forwarder selected by the company I work for and files […]
QUESTION: With regard to the section 301 China tariffs exclusion form question 10, it asks you to provide the value for the previous 3 years. If the HTS code calls for “X” as the quantity, do you leave the quantity blank or would you provide some type of quantity such as how much you ordered […]
QUESTION: We are putting temperature controlled monitoring devices in reefer containers that will be exported from the US.Device is reusable, approximately $35 in value and the ECCN is EAR99.Do we have to declare these devices on our shipping paperwork or would we treat these as instruments of international trade?************Answers: You can treat them as part […]
