Question: Does anyone have a strong opinion on this decision? I would think the government agencies such as EPA, FDA, etc. could be significantly impacted by this decision. Does anyone foresee turmoil in the future of trade compliance? Answer 1: I think it cuts both ways. I think there are fewer enforcement actions and agreements, […]
Question: Do any members have experience with Project Shield America, an Outreach Program from ICE / Homeland Security Investigations? If so, what has this experience been like? Is there benefit from engaging with the regulators in this program / receiving the visit and presentation materials? Are there downsides or risks? Is this sometimes a precursor […]
Question: We import material that requires a USDA Permit. We have an R&D Permit and we have a Commercial Permit. The material that is imported are samples from production batches that will be sold commercially. These samples are tested for purification, toxicity, quality etc. So, I would not consider them to be R&D because the […]
Question: Does anyone have a USDA decision tree to help trade compliance specialists determine if an imported item needs a USDA Permit or if a GS is sufficient? Answer 1: https://efile.aphis.usda.gov/s/vs-permitting-assistant Hope this helps.
Question: My company imports Reagents and Certified Reference materials which are antibodies developed in Mouse, Rabbit, Human, Alpaca and Llama to detect certain Protein Receptor Binding Domain (RCB). We are importing under HTSUS 3822.90.0000. The OGA flags FD1 & AQ1. It has been suggested that we need to include a USDA Guideline statement (1120 or […]
Question: We are reviewing the requirements for labeling a product as “Made in the USA”. US Customs addresses waste/recovered products in the definitions under 102.1 but I do not see where the FTC addresses this in the regs under title 16 for made in the USA labeling. They specifically address recycling oil but do not […]
Question: We are importing a saline solution placebo composed of .9% sodium chloride, minute amounts of hydrochloric acid and sodium hydroxide in 99.1% water. This is to mimic the experience of an injectable medicine. We are trying to determine the most appropriate HS Code to use. We considered 2106.90.9998 but figured that this is usually […]
Question: Can anyone explain the difference between Customs Release and FDA Release? Can a shipment that has been released by US Customs be moved to the final delivery site or to an interim location until FDA Release has been received? Keep in mind that the goods would be put into a location of the warehouse […]
Question: We are trying to register with DLA and keep getting rejected for various errors. Seems time to get expert help. Any recommendations for experienced help with DLA form DD2345? Answer 1: They have an email ( JCP-ADMIN@DLA.MIL) and a phone # – so as with anything, if you have trouble then you have to contact […]
Question: Where can I find information and updated forms for PGA/OGA flags including FDA, TSCA, APHIS, etc? What regulations govern these? I’m looking to do a deep dive in to ALL PGA/OGA flags. Answer 1: Your Customs Broker should be able to provide you a list of HS Codes and corresponding OGA flags. Just ask […]
Question: Hello, Can someone in the community please provide us a list of countries that are subject to comprehensive sanctions based on U.S. government regulations/instructions? Thank you. Answer 1: There’s no U.S. “comprehensive sanctions” list per se, but, as commonly understood, that term would apply to: Cuba, Iran, North Korea, Syria, Crimea, Donetsk People’s Republic, […]
Question: Is there somewhere in ACE or the internet that I can get a list of the HTS that are flagged for PGA (e.g. FDA, EPA, APHIS) etc.? It seems the broker is privvy to this when performing the entry, but I’m not seeing where in ACE or elsewhere I can have that same information. […]
