Miscellaneous

QUESTION: U.S. regulations state that we may not export to, or compensate, an individual that is on the restricted party lists.  Screening is the mechanism to ensure compliance. How frequently do companies rescreen their employees against restricted party lists? Could you share how do you ensure compliance with the above without periodic rescreening of employees? […]

QUESTION: Would any of the members be willing to share some of the language that they use in contracts with material suppliers that provides coverage regarding expectations for Customs Compliance/International Trade activities? ================== ANSWERS: I’d recommend looking online.  In particular search for “international purchase order” and “international supplier agreement.”  Many companies post these documents online […]

QUESTION: We shipped a full container of machinery spare parts with an incorrect Commercial Invoice and Packing list that did not acknowledge the inclusion of one Crate of Parts that were in the container.  The container cleared customs and the crate of product worth about $20,000 was discovered by our Dealer.  The clerical error on […]

QUESTION: We have a US customer, that we make a sale to domestically. The product comes from overseas and we ship it directly to our customer (from our manufacturer), they are the importer of record (the US customer).   From my standpoint, this is a domestic transaction. We have been doing all the paperwork, indicating […]

QUESTION: With regards to MID Code construction, CBP requires “the ISO code for the actual country of origin of the goods” as the first two characters.  However, our vendor invoices note a different country (e.g. CoO CN and Commercial Invoice address Taipai Taiwan) such that our broker is using TW as the first two characters. […]

QUESTION: Is using the Consolidated Screening List on export.gov sufficient for showing due diligence for all of the sanctions and denied parties checks?  Are there any sanctions or other lists that should be screened that are not on the CSL? ********* Answers: If you are a small entity with no overseas business it MAY be […]

QUESTION: I’ve been asked to “weaponize trade compliance” at my new job. I think that the best way for me to do this is to show how trade compliance can actually make a company more efficient and give it a competitive advantage. Can anyone suggest any resources (white papers, etc) on how best to present […]

QUESTION: We are an importer of record and purchase from a related party overseas. We have received a retroactive price contract from one of our customers. The invoice value we used at time of entry is the pricing we had on file. Now we have the new pricing on file and it is retroactive. We […]

QUESTION: What is the date used to assess duty rate? ·         For consumption entry ·         If an I.T. is applied Warehouse entry withdrawal ========== Answers: This all covered in 19 CFR 141.68 – the date for duty calculation can be elected by the filer for a consumption entry – it can be the date the […]

QUESTION: What are the payment terms generally used by the majority of the membership for international vendors; payment before goods are received, payment after goods are received, etc.? ========== Answers: The best terms to push for are the ROG terms and if you can get additional days it’s a bonus; however, the most common payment […]

QUESTION: I am looking for originating rules for the EU Honduras trade agreement. This is for apparel. Does anyone have a good resource for FTAs not involving the US?,,Thank you! ========== Answers: Most North and South American FTAs may be found on the OAS website sice.oas.org. Your particular agreement is part of the Central American-EU […]