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 […]
We are in the process of sending a BOM, drawings and components to our China sub contractor so they can build us production quantity circuit boards. Also, we will need to send them drawings and schematics of a test fixture that they will need to test the circuit boards prior to shipment. The circuit boards […]
Does anyone have experience related to EAR99 software sold to foreign military organizations (proper due diligence completed), and for which follow-on consulting service might be considered a defense service if the consulting provides guidance on how the EAR99 software might be used to enhance, improve, modify, etc., defense articles of the foreign military? For example, […]
I have a question about the scope of goods subject to the US EAR. Obviously goods that are made in the US are subject to the regulations, as well as any goods that are physically exported from the US. How does this tie into the re-export concepts in the EAR? Would goods (of any origin) […]
