Question: Quick question for the membership about record keeping. Let me preface the question by saying we do not operate an FTZ however we do have a custodial bond. Through some company re-organization I came across a load of files (7512, HAWB/OBL, Invoices and Packing lists) for in bond shipments. I’m considering throwing them […]
Question: I have read conflicting information on notifying customs if you are considering electronic storage of import documents. I have read a couple articles on the customs website that you must notify customs that your company is moving to electronic data storage. I have also read on several consulting websites that this is no longer […]
Question: OK, what gives with keeping records of U.S. exports of data that are non-licensable? Every company I’ve talked to seems to keep records (some sortof log) of data exports which are licensable (BIS license, BIS exception,ITAR license, ITAR agreement etc.). However, I have yet to find anyone whokeeps records of ALL exports of data. […]
Question: We have recently notified reg audit of our intention to store our customs records via an alternative storage method. (PDF’s on a company network off of CD’s received from our customs brokers) They have indicated in a letter back to us that we must we must paraphrase (verbatim) all six standards listed in 19 […]
Question: We are having issues on recordkeeping requirements for export records. Presently we keep our records electronically in a backed up drive. We now have a situation where we have a new situation where we are consolidating large orders. Scanning these larger orders is very labor intensive. We are looking at keeping these orders […]
Our company has global reach and we currently export goods from the States to our Asia Pacific, EMEA and Canadian markets. We currently keep export docs on a Sharepoint site, however with the business growing and changing, our export compliance and the relationship with our export freight forwarder will now be handled by each region […]
Our export recordkeeping program is somewhat archaic and disjointed – but at the end of the day – we do have access to all of our records if/when asked for. We, as well as our 3PL, keep an ‘export folder’ on each order with hard copies of all pertinent and required documentation as per the […]
Question: We have small part suppliers who purchase material for us. These suppliers buy from the most economical source at the time we place our order. Therefore, the supplier may purchase a part from Country A on one order and purchase that same part from Country B on the next order. We are trying […]
What are the record keeping requirements for ATA Carnets? Does the record keeping requirement begin when the export takes place, the import take place, or once the carnet expires?
Questions for those in the apparel industry: Illegal transshipment can occur in any country, obviously some more likely than others. Since we are on the hook to maintain records for five years, we require our factories to also maintain records for five years to support origin. Cutting and sewing tickets are typically important records to […]
How long are exporters required to wait before destroying ITAR controlled export records? Does ITAR have a specific time period in which export records must be retained (similar to the 5 year time frame Commerce specifies in the EAR)?
I have been challenged to change our record keeping system as allowed in 19 CFR 163.5. Presently, we receive hard copy documents from our broker that includes their invoice, CF7501, CF3461, and all commercial invoices & back up documents. We are also suppose to receive any emails that relate to that specific entry as they […]
