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The Import Side of Export Compliance

Important issues to address when exporting product from the U.S. include ensuring that appropriate export licensing authority, including a license or applicable exception/exemption is provided for that export sale; and that shipment certifications are obtained.

There are, however, other important considerations and provisioning that should be addressed and provided for with regards to the return to the U.S. of exported product or parts.

Exported product can be subject to return to the U.S. for various reasons including: shipment error (wrong part, excess quantity of parts shipped); quality issue; return for overhaul and repair, upgrade, retrofit; retesting, recalibration, etc.

Import of items into the U.S., whether purchased items or items previously exported from the U.S., must be cleared through U.S. Customs and comply with U.S. Customs laws and regulations.  These requirements include submittal of a commercial invoice from the foreign company identifying the items and detailing required information including (quantity, value, country of origin).

Also, depending on the items being imported, U.S. Customs clearance and permitted U.S. imports will be subject to the items being properly marked as to country of origin and meeting other applicable U.S. import and export laws and regulations.

If the items being imported were originally exported under U.S. export license or other export-controlled authority and were items for temporary import (i.e. to be returned back to foreign exporter), it may be necessary on U.S. import to identify the original export licensing authority and intent to return the items being imported.

Companies need to ensure, as part of their U.S. export controls, that they evaluate and create controls over the U.S. import of items (product, parts or support equipment, etc.) including products being returned to the U.S.

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