Question: We have a subsidiary company in China actively selling our EAR99 product. They have recently found a customer in China that appears to be set up as an import/export company and they want us to ship to multiple ports throughout China. Searching the company on the internet, I find they have been named […]
Question: What factors must a company consider when being asked to ship an EAR99 item to Iraq?
Question: For those of you who may sell a product that requires an export license to ship to a large number of countries (for example, National Security, Column 2), do any of you include any notice with the shipped product, when selling to a customer in a country that doesn’t require an export license, […]
What is the shipper’s obligation concerning export control with their distributors (domestic & International) on sending an EAR99 shipment? Do you ask your distributor for the end-user? Can the membership please share their process they have in place concerning distributors.
Can you please tell me how you comply with the EAR General Prohibitions 4-10? (Checking “bad guy” lists.) Do you have a manual process, in-house software, website access, software fully integrated into your ERP system, or some other way? If you use software, do you also check other countries “bad guy” lists? Do you check […]
A US semiconductor company designs and manufactures commercial products (no military). The design technology used to design the ICs is classified under the EAR with an ECCN of 3E991 while their products are 3A991. The company considers their technical design data as an IP only because of the unique way in which they assemble the […]
Can anyone tell me if there is a website that contains the Export Administration Regulations that are free? Also, is there some type of export licensing for individuals like there is for imports?
If company A finds out that their customer’s, customer, (3rd tier) is exporting U.S. goods or technology to a country in Country Group E, are the export regs specific in stating that company A “MUST” report the violation of EAR? In 746.4 of the EAR, it states that “If a person learns that an export […]
The EAR does not require exporters to submit form 748 for classification request for all your products. You are allow to self classify your products, except for Encryption items. When should you really apply for an official classification request? If you believe that your product is EAR99, would you still apply for classification request (to […]
How does the membership proactively notify their customers of the end use/end user requirements of the EAR? Is the draft letter below comprehensive enough to notify customers of their responsibilities? What other steps should be taken, if any? How often should the customers be proactively notified? US Export Regulations require ####### to take reasonable steps […]
Does anyone have jurisdiction experience with this scenario: *Several EAR99 parts (std nut, washer, bolt etc.) are combined into 1 part # and sold as a “kit” to a military applicaiton. So the parts, if sold “separately”, would be Commerce jurisdiction / EAR99. Does the action of combining them to sell as a kit under […]
Question: Has any member ever been told you must have a firm order before you can apply for a license? If so where does it state this in the EAR? Also our company is looking at selling our product to a company in China for the aerospace industry. It does require a license through BIS […]
