QUESTION: If company A is on the DDTC / ITAR debarred list, can we still work with Company A on BIS/Commerce controlled Dual-use items? ========== Answers: As long as you are exporting an EAR controlled item and there are no published restrictions in the EAR on exporting to the entity, then yes, although I might […]
QUESTION: It was recommended to me there should be a clause on customer/distributor contracts with regards to EAR regulations. Something to say that we as U.S. company therefore we require parties abide by EAR regulations and prohibits from shipping or transship to sanctions countries; or something in that verbiage. Questions – is it best practices […]
QUESTION: My freight forwarder is telling me that it is not necessary to have EAR99 appear on the EEI. Is there a downside to having the EEI state EAR99 even though it may not be required? From an auditing perspective, I prefer to have the EEI state EAR99 but perhaps I am overlooking something. ========== […]
QUESTION: I’d like to query the group on the process involved with the licensing of a Non-US employee who one of our business divisions has decided need to come to one of our US facilities to assist with a production process that is currently struggling due to loss of experience. The employee is from Country […]
QUESTION: You have an overall system designed for the removal of metal and other materials by laser which is called out in 2B001(e). The laser is mounted to a robot as a articulating arm. The full system does not meet the accuracy called out in 2B001(e). The two components if shipped by themselves fall […]
QUESTION: Currently, the Commercial Invoice includes the Destination Control Statement for all our export transactions from the US. However, with the new Destination Control Statement effective on November 15, 2016, I’ve heard that some companies include the statement for their domestic transactions as well. Is it standard practice for companies to include this statement on […]
QUESTION: FR Vol 81 No. 159 outlines the new DCS and states it will go into effect November 15, 2016: Do you think it is okay to initiate the change in export documentation now? *************** Answers: I’m sitting at a BIS conference now. They said yes on using the new DCS now for BIS but it […]
QUESTION: On July 28th 2016, AES began decrementing the BIS license value and will sometimes return some Informational Messages to the filer. One of those messages states €œthat the allowable shipping tolerance (10% over BIS license value) has been exceeded by the current filing.€ We find it strange that we have never heard of a […]
QUESTION: We are making an automotive fender as a Tier 1 production Supplier per Customer specs to be shipped to the Customer assembly plant within the US. The Customer is requesting ECCN on the RFQ. I am not an EAR expert but the only way I can see EAR applying to this part is if […]
QUESTION: I am new to Department of Commerce EAR. My company office in Atlanta GA USA would like to ship bearing products to a customer in the Philippines via our office in Hong Kong. If I am reading the CCL and CCC correctly, reason for control RS applies. Does this mean I will need to […]
QUESTION: My company is subject to both the EAR and the ITAR. I have a question about hiring a person who does not meet the ITAR or EAR definitions of a U.S. person. This is for a U.S.-based engineering position, and the official job description requires access to export controlled technology or technical data. In […]
QUESTION: Say you have an EAR item that is a component of a system or assembly that when shipped by itself is a licensable item. But if it is installed within the system/assembly that is not licensable there is not license requirement because the EAR does not have a “see through rule” like the ITAR. […]
