Miscellaneous

MISCELLANEOUS

  • CN TARIFF COMMENT PROCESS

    QUESTION: Is there a process importers are following to comment on the latest rounds of China Tariffs? ================== ANSWERS: Regulations.gov USTR-2018-0026 ======================== There sure is: https://www.federalregister.gov/documents/2018/07/11/2018-14820/procedures-to-consider-requests-for-exclusion-of-particular-products-from-the-determination-of  

  • SEC 301 TIMELINES

    QUESTION: Would the membership advise where we are currently in the Sec 301 additional tariffs announced by the USTR?  As I understand, List 1 was effective 07/06/18 and duty rates are 25%.  List 2 is currently in the comment stage and duty rates are 25%.  The final list, made public by the USTR last week, […]

  • SHIPPED LOOSE VS ITEMIZED ITEMS

    QUESTION: We ship large assemblies, disassembled for shipping, and include the nuts, bolts, struts, etc that are required for the re-assembly as “Ship Loose.” (Nothing extra, no spares.  Just the things that come off it when we take it apart.) That’s ok if the “ship loose” travels with the disassembled unit. But, if the “ship […]

  • Miscellaneous Tariff Bill and Section 301

    QUESTION: Are the items on the Miscellaneous Tariff Bill going to be subject to Section 301 duties? ========== Answer: There is talk  that Trump may not sign the Miscellaneous Tariff Bill, because it is counter to his current trade policy. George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite […]

  • TPL PROVIDER AS A BROKER

    QUESTION: If a third party logistics provider’s business model is to provide warehouses around the world, and on behalf of clients will facilitate freight forwarders to process the goods as they move, is this 3PL considered a “broker” and/or in other ways considered exporting/importing? ************ Answers: There is no easy answer as there is not […]

  • MTB H.R. 4318

    QUESTION: Someone in my organization asked me how the Miscellaneous Tariff Bill (MTB), also known as H.R. 4318 would affect our organization. I couldn’t find much about it online, nor a list of the tariff codes impacted. Has anyone else been following the Miscellaneous Tariff Bill, or is it too soon in the process to […]

  • SHIPPED LOOSE VS ITEMIZED ITEMS

    QUESTION: We ship large assemblies, disassembled for shipping, and include the nuts, bolts, struts, etc that are required for the re-assembly as “Ship Loose.” (Nothing extra, no spares.  Just the things that come off it when we take it apart.) That’s ok if the “ship loose” travels with the disassembled unit.But, if the “ship loose” […]

  • CEE Management Visits

    QUESTION: We were just informed by CBP CEE personnel that they would like to do a “Importer Visit”.  We have quarterly calls with CEE personnel but this is the first time they have asked to come on the premises.  They also want to visit one of our local factories.  Can anyone share their experience?  Do […]

  • New Global Trade Director

    QUESTION: We are a Fortune 500 Company headquartered in the U.S.  Our current Director of Global Trade Compliance is moving into a different role within the company, and we have a new Director of Global Trade Compliance who will be located in Belgium and is not a U.S. citizen.  Are there any concerns about having […]

  • Question on 19 CFR 192.1 and 192.2

    QUESTION: Would a bus, with the engine removed, be considered a self-propelled vehicle as defined in 19 CFR 192.1 and subject to the requirements of 19 CFR 192.2 upon export to Canada? ================= ANSWER: If the engine has been removed, I would think that the bus does not fit into the definition in 192.1 and […]

  • SEC 301 TIMELINES

    QUESTION: Would the membership advise where we are currently in the Sec 301 additional tariffs announced by the USTR?  As I understand, List 1 was effective 07/06/18 and duty rates are 25%.  List 2 is currently in the comment stage and duty rates are 25%.  The final list, made public by the USTR last week, […]

  • AUSTRALIAN STINK BUG COMPLIANCE

    QUESTION: I am concerned the cost for fumigation and delays in importing could hurt our customers. I have read DAWR requirement for Brown marmorated stink bug (BMSB). The fumigation will be required for most products from Sept 1 2018 to April 30th of 2019. Any ideas for dealing with this costly process ? A long […]