Question: If I have an item that falls under EAR99 classification, when is a license required? Does it only require a license if it’s being shipped to one of the five debarred countries? ********** Add’l Answer: No – you need to also check the name of the person you are sending it to – if they […]
Question: How are companies managing the requirement to log technical data exports under the EAR? Are you logging the export of technical data for everything; everything except EAR99 technical data; or only licensed technical data under the EAR? ========== Answer: Not sure what requirement you are referring to? Are you thinking of the 762 recordkeeping […]
Question: We manufacture electronic equipment that we have designated as EAR99. However, recently I was informed that some of our products with this designation contain MMIC power amplifiers. Do we need to make a classification determination based on the MMIC amplifier within the final product, or the final product performance and technical characteristics itself? ========== […]
Question: Our company builds products that are classified EAR99. There are some components that are controlled but usually just for AT. Also, the controlled components are available to the general public for purchase. My question is regarding plant tours. We are trying to decide if it is necessary to screen all individuals that we are […]
Question: If our wholly owned UK subsidiary wants to ship an EAR99 product to a sanctioned country, does the US headquarters have to apply for a license on their behalf? *********** Answers: Since U.S. regulations require U.S. approval for reexports of controlled U.S. technology, I believe the UK subsidiary can request those licenses directly. But […]
Question: I’m curious to know, what the membership’s view is regarding the need to obtain End User Certificates (EUC) prior to the export of their products. Do you obtain EUCs for every export, even EAR 99 or do you obtain EUCs for products classified under certain ECCNs (i.e. those ECCNs that have more than AT […]
Question: Does the FPPI letter from the Foreign Principal Party of Interest require an expiration date according to the regulations ************ ANSWERS: No. Authorization is valid until revoked by FPPI. ************ The letter does not have to contain an expiration date. It can be dictated to whatever parameters the shipper/consignee agree. It can be for […]
Question: In several places throughout the EAR, the words “controlled for national security” are used. Does this refer to “NS” controls only on the CCL, or is “national security” generalized to include all reasons for control? I have seen places where it specifically says “controlled for National Security (NS)” and then I have seen “national […]
Question: A customer in the EU has asked us (US exporter) about Dual Use items. I have heard of dual use, but don’t fully understand it. We used to have ITAR items, but now everything we have is under the EAR – either 600 series or another ECCN. Can the membership provide any references or […]
Question: Just confirming my understanding with this question. Test equipment (EAR99) ships from the US and the sole purpose is to test gaskets and seals at our supplier’s factory in Asia. The equipment is solely used for testing and nothing else, but it has a computer with a touch screen installed onto this tester at […]
Question: Does anyone out there have any insight into why the applicability of the definition of “required” in §772 of the EAR is limited to Categories 4, 5, 6 & 9? ************** Answers: You need to link the term “required” to the General Technology note in Part 774 Supplement 2. Then I think that it […]
Question: I work for a confectionery company and all of our goods are EAR99. We screen parties involved in the export and do not ship to prohibited countries. Since our goods are EAR99 and perform export control, do we need to receive an End User Statement or Letter from foreign buyer? Answers: As you […]
