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 […]
May I please have your kind assistance? I am putting together a business case arguing the merits of and necessity for a corporate Customs compliance department. Currently, our billion dollar company is decentralized and each division/subsidiary/etc. is doing their own thing in regards to Customs compliance. This puts our company at risks on several different […]
We have recently had a department meeting concerning our Pro-Forma Invoice and Export Documentation. After reading about the recent interest by Census regarding Routed Transactions and the legal responsiblities for AES filings, our document statements may be lacking in protection for the company in case of an audit or International litigation. I have found the […]
We have someone overseas who is requesting a quote for some EAR99 parts. He is a distributor and wants to purchase these for his stock. Is there anyway we can sell these without the specific end use/ end user? Is there something he can sign or do so we know it?s all legal? Thank you
My company now manufactures products controlled for NP in the US and > might have more tightly-controlled product on the way. We have > distribution centers scattered around the globe, including in the > EU, which distribute to many countries in their parts of the world. > Are there any resources or advice as to […]
