Clarification on the Incoterm CIP

16 April 2018

My company currently ships to many destinations in the Middle East using the Incoterm Delivered at Place (DAP) rule, although we are now considering whether it would be better to use the Carriage and Insurance Paid (CIP) rule instead.

Could you explain the following requirements when using the Incoterm CIP in terms of:

  • insurance requirements as a seller

  • documentation requirements as a seller for both customs and our customer.

What documentation is it necessary to complete? Is it still necessary to create documentation to clear customs at the receiver’s end?

Receiving controlled goods from the USA with no export licence – can we use them?

9 April 2018

If we receive parts into the UK from the USA with an Export Control Classification Number (ECCN) of 3A611.X and 3A611.Y, indicating controlled goods under the US Export Administration Regulations (EAR), but the supplier has failed to use a US export licence do we have to quarantine them on arrival until they have obtained a US export licence or can we use them?

REACH and Brexit – further questions

28 March 2018

I read a couple of interesting REACH-related Q&As recently on Croner-i International Trade (REACH – Only Representative status and REACH registration) and it has made me consider my company’s situation regarding REACH. The company is a UK-based “Only Representative” for an American chemical business for its sales into the EU; we have also registered goods in our own right that are manufactured and imported from outside the EU. Our EU market is about 70% of our export sales, so the thought of being excluded from REACH when the UK leaves the EU is very worrying. Can we set up a company on paper only in one of the EU-27 Member States and transfer our REACH registrations there?

Can I complete one customs declaration for two items from different suppliers?

22 March 2018

A bonded warehouse provider is insisting on us clearing goods out of their warehouse by creating an individual entry per supplier. They told us that clearance must mirror the import entry into the warehouse. For example, Supplier A imports 150 widgets into the bonded warehouse and Supplier B imports 200 screws. If our factory pulls in 100 widgets and 100 screws are we required to give entry instructions for two customs declarations (one per supplier), when we only want to enter the widgets and screws on a single import entry?

Importing plastics into Saudi Arabia

22 March 2018

My company exports goods to Saudi Arabia and has become aware of new regulations concerning the import of plastics into that country, ie that from December 2017, any plastic products imported into Saudi Arabia need to be made of a biodegradable material. While we do not send plastic products, we do use plastic packaging which, we believe, is also covered by the new regulations. It appears that a licence is required to import biodegradable plastic products into Saudi Arabia, but we are not sure if a licence is needed if we simply package goods in biodegradable plastic.

There is limited information available online and what information we have found seems to be contradictory. The majority of our exports are sent to Saudi Arabia and we do not want shipments held up because of a lack of understanding of new regulations.

Can we retrospectively reclaim duty for past shipments?

16 March 2018

We have recently been authorised under the Registered Exporter Scheme (REX) for our company to supply EU-originating product shipped to Canada under the Comprehensive Economic Trade Agreement (CETA). We have only just recently (December 2017) been approved, although we did make shipments to Canada in September and November and we wondered if were able to retrospectively reclaim the duty for these shipments. Is this possible?

Dual-use controlled parts for end user in Pakistan

16 March 2018

We are selling some dual-use controlled parts (Category 3A001a2c) to a company in Spain who will incorporate them into a system for an end user in Pakistan. We plan on shipping the parts with the following statement: “3A001a2c ― goods may require a licence if shipped outside the EU”. Is this the correct one to use?

Dangerous goods movement — what are my responsibilities?

12 March 2018

If a product we are selling is hazardous for transport what are our responsibilities as the seller in terms of paperwork and packaging for a dangerous goods movement given that we are not always aware of the mode of transport the consignment will be moving via? I am not familiar with the Incoterms® rule Ex Works (EXW), but my colleagues use it frequently for shipments from the USA. Does this apply?