QUESTION: I have a couple of questions regarding encryption controls. We have a piece of equipment, a router, listed on the OEM website with ECCN 5A002A1 740.174(b)(2) because of the encryption, but our customer is telling us that they removed all encryption from the device. Does this then mean that regardless of OEM website, the router […]
QUESTION: I have an example transaction where I am having a hard time defining who is responsible for the importation of a shipment and could use some advice from the Community. We place a purchase order to a domestic supplier under FCA Incoterms with no defined destination as our ERP system is not set up, […]
It’s time for our annual Fall Scholarship program. The ICPA scholarship is available for regular (non-service provider) paid members of the organization and any unmarried dependent children of the member under 25 years of age. The deadline for the completed application & essay is noon/CST on July 15, 2022. Please read and follow the instructions […]
QUESTION: What permits / considerations are required to ship a commercial veterinarian drug product to the US for in vivo research if that drug is not approved for use in the US? ========== Answer: This link may be a good starting point for you Importing – Veterinary Drugs https://www.fda.gov/animal-veterinary/import-exports/importing-veterinary-drugs Add’l Answer: You generally want to […]
QUESTION: I’m looking to beef up our risk assessment procedures as part of CTPAT membership. Would anyone be willing to share the information they use to help conduct the threat assessment portion of the 5-step risk assessments? ****************** Answers: You can use, www.cia.gov Alejandra Madrigal Director, Global Trade Compliance & Logistics Solutions Address: 256 Post Road […]
Is there a different term that we could be purchasing under that covers the transfer of risk at the same level, so our customs broker does not deduct these fees from the entered value? Simply advising them not to deduct the charges may not work effectively…. *********** Answers: Try FOB ************ The reason your broker […]
QUESTION: Does ECCN apply to PCB evaluation board ( without software) designed to change the channels of optical transceivers ? I went through category 5 : ECCN for optical transceivers is 5A991 ( sold separately) Couldn’t determine / find anything related to the basic printed circuit assembly evaluation board to be used for programming ( […]
QUESTION: I cannot locate any CBP publications that state whether articles made in Taiwan and imported into the US should be labeled with country of origin of: “Taiwan” or “Taiwan R.O.C.” . Does anyone know what is definitively required? ************** Answers: For U.S. import, there was recently a change to the marking requirements for Hong […]
QUESTION: Is anyone aware upcoming elimination of incandescent bulbs and if so, do you have any information regarding this? ========== Answer: Go here: https://www.epa.gov/mercury/how-energy-independence-and-security-act-2007-affects-light-bulbs https://www.cnbc.com/2022/04/26/biden-blocks-sales-of-inefficient-lightbulbs-reversing-trump-policy-.html The new reinstated rules are here: https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=4 George Tuttle IIILaw Offices of George R. Tuttle, A.P.C.3950 Civic Center Drive, Ste 310 San Rafael, CA 94903 **Please note our new address […]
QUESTION: Does anyone know where I can find some good regulatory guidance on the following: Company A is exporting under a BIS license a replacement CPU for ECCN 9A610.f Military Aircraft Ground Support Equipment. Company A plans to send engineers to the foreign customers onsite facility to remove the defective CPU and install the replacement. […]
QUESTION: Does anyone in the membership have an English language copy they can share of the list of products approved for parallel import which was published by the Russian Ministry of Industry on May 6, 2022? %%%%%%%%%% ANSWER: The document contains 25 pages with over 50 groups of commodities included in that list. The Ministry […]
QUESTION: Does any know where to find all current US sanctions against Russia? Question is being raised by our sales if our EU distribution can still sell to a new customer there. %%%%%%%%%% ANSWERS: The simplicity of your question suggests you may not be aware of the complexity of the answer. There are financial sanctions and […]
