Classification: Export

Questions and answers about Classification: Export

  • STA Eligibility

    Question: Is 9E619.a and 9A619.a eligible for STA? Shipping a part to Sweden and would like to use STA if possible. Answer 1: Directly from the EAR, Supplement No. 1 to Part 774 – The Commerce Control List Under 9A619: List Based License Exceptions (See Part 740 for a Description of All License Exceptions) LVS: $1,500 GBS: N/A Special […]

  • New HTS not allowed in AES

    Question: We generally use HTS codes for export, but one of our codes is no longer accepted in AES. Does anyone have advice on interpreting the breakdown of 8517.62.0030 – 8517.62.0080?  Our technical folks are getting hung up on thinking that multiprotocol can only include the three options before it (Wifi, Bluetooth and proprietary).  Do […]

  • Export of Technology Containing more than one ECCN

    Question: Looking for documented support/justification (regulatory, SMEs, best practices) for why Trade Compliance uses the more stringent classification in a situation like the stack of drawings with varying ECCNs, such as EAR99 and 3A611.x, to be sent to a supplier.  The end use is to provide technology needed to design/develop a machine which will be […]

  • Containers of international traffic

    Question: We have containers that we ship back empty to our suppliers that they use to fill and send us our parts back into the US.  Currently we are not claiming chapter 9801 on the import side.  For exports I am currently using the classification of the containers.  My question is since ownership does not […]

  • Teledyne J69 Engine

    Question: Can you please advise if parts, components, accessories and attachments to the J69 engine is still under the jurisdiction of ITAR?  Or if this is part of the Export Reform that’s been migrated from ITAR to EAR? Asked by: Brenda Lumagui – Answer 1: First, we have to know how much power the […]

  • ITAR or EAR

    Question: There is this statement in paragraph (h) of Cat VIII: h) Parts, components, accessories, attachments, associated equipment and systems, as follows: (1) Parts, components, accessories, and attachments specially designed for the following U.S.-origin aircraft: The B-1B, B-2, B-21, F-15SE, F/A-18 E/F, EA-18G, F-22, F-35, and future variants thereof; or the F-117 or U.S. Government […]

  • DOD CUI vs Export Control

    Question: Is it accurate to say that Controlled Unclassified Information (“CUI”) in US DOD speak translates to SOME export control classification under either the EAR or ITAR (e.g. could be EAR99, any ECCN or any USML)?  So all CUI is subject to export regulation. Answer 1: CUI and U.S. export-controlled information overlap like a Venn […]

  • classification

    Question: how would ICPA classification experts classify a crankcase for an air compressor?   would there be an ECCN or would EAR99 suffice? Answer 1: There is not enough information to give an accurate answer. The HTS is probably in 8414. The ECCN for the crankcase will be determined by the ECCN for the complete compressor […]

  • virtual reality goggles

    Question: Does anyone have any experience with coding virtual reality sets for both HTS and ECCN.  We are looking to send a set to our parent company in Italy for demo and evaluation.  They are used in training situations. thanks  Answer 1: CBP has several rulings on the tariff  classification of these articles.  See for […]


    QUESTION: Currently, we have an outside 3rd party submit BIS ENC/Mass Market Classification Requests for our products and reviewing pros/cons for submitting internally instead.  We currently file own export license applications and other classification requests through SNAP-R. What are some of the potential downfalls or words of wisdom we should review for submitting own BIS […]

  • 8544.42.000 vs HTS 8544.70.0000

    QUESTION: We are exporting fiber optic patch cable with connectors on both ends.  Both HTS codes referring to fiber optic cables with connectors.  Can someone specify the correct HTS to be used ? HTS 8544.42.000 vs HTS 8544.70.0000 %%%%%%%%%% ANSWERS: It depends on the maximum voltage the cable was designed to conduct/carry. %%%%%%%%%% Cables of […]


    QUESTION: We recently applied for and received an export classification letter from CBP. The result was not what we feel is correct, nor do two different outside consultants that we used. We know we can appeal, but who hears the appeal?  The same team that provided the original result?  Or different people? %%%%%%%%%% ANSWERS: Not […]