QUESTION: We recently received the commodity classification result from the BIS for our NEW software that will be used for our devices. The result is ECCN EAR99 which basically means we are now free to do anything with the software, except sending them to the US embargoed countries. The OLD software was previously classified by […]
QUESTION: If items subject to the EAR are exported to Country A and then subsequently re-exported to Country B, is the re-exporter required to include the Destination Control Statement on their export paperwork? ========== Answers: If the items are U.S. origin, yes. Do companies overseas adhere to it? Most likely not, but I am seeing […]
QUESTION: We have filed EEI for EAR99 product. After vessel’s departure customer has requested to change the final destination of the container within the same country. If we process with COD request, should we amend EEI filing (post departure) to reflect the correct discharge port? Will it be considered a compliance issue? We are concerned […]
QUESTION: I found out that equipment that my product is used in as an “attachment” is on the CCL Alphabetical Control List and has an ECCN number but my product is not on the Alphabetical Control List. While I do not see the name of my product on the Alphabetical Control List would it be […]
QUESTION: The scenario is shipping automotive parts, US finished goods(EAR99) to a subsidiary located in the EU. I have read through 31 C.F.R. 560.215 showing prohibitions to Iran. There is an exemption under General License H that allows you to ship items that don’t have a license. However, on Oct 13, 2017 President Trump chose […]
QUESTION: I am working with senior leaders in our company to establish an HR policy on hiring of foreign persons. The company has recently consolidated a number of separate entities under a single company here in the US. We are incorporated in the US, but foreign owned and ITAR registered as a manufacturer / exporter. […]
QUESTION: Does the Export Administration Regulations state anywhere that one dedicated individual needs to be named as a point of contact relating to export functions for a company or corporation? ========== Answers: No. ========== Refer to 30.6 (iv) of the FTR “USPPI contact information. The person who has the most knowledge regarding the specific shipment […]
QUESTION: Recently some EU companies say they can ship any US-purchased parts to Iran, as long as the parts are EAR99. Where is this coming from?? ========== Answer: Absolutely not possible. Unfortunately the EU regulations are MUCH more relaxed with Iran then the USA, and just about all companies I have spoken with in Europe […]
QUESTION: Where in the EAR does it indicate who can view a BIS export license? Can a paper copy of the license accompany the shipment if the actual license gives no indication of confidentiality? ========== Answers: Why would anyone need to send a copy of the export license with the shipment? I believe those records […]
QUESTION: Our company exports goods that fall under EAR-99. The Export Compliance Guidelines in the BIS website recommends that a Management commitment statement be signed by the President or CEO of the company to be distributed to all employees on an annual basis. I forwarded the example statement (below) to the head of our legal […]
QUESTION: We are a foreign entity located in Mexico and manufacture EAR600 as well as ITAR goods, the US customer does have a BIS license as well as DDTC licenses in place and we are listed on these licenses. My question is: if the foreign Mexican entity sends tech. data to a US supplier for further […]
QUESTION: We manufacture and export EAR99 food products. We are re-visiting our new customer application form to ensure we are capturing the necessary areas of risk for denied parties screening (I’m using this term broadly for the screening of 100+ govt lists). What are some best practices for creating a new export customer application form […]
