EAR

Questions and answers about EAR

  • RED FLAG SCREENING

    Question: Has anyone implemented a  red flag screening checklist/form (to document compliance with EAR Supplement No. 3 to Part 732 – BIS’s Know Your Customer Guidance”).   If so, is it maintained at the customer or order level?   Finally, if it’s done at the customer level, is it only done once at the time […]

  • END USERS

    Question: I am having a debate with my business colleagues regarding whether the OEMs (Original Equipment Manufacturers) we sell to are considered end-users from an EAR perspective.    We sell and export devices to OEMs that they incorporate into a larger piece of equipment that they sell to ultimate end-users, typically (but not always) in […]

  • EAR BEST PRACTICES Additional Answers

    Question:   I am currently setting up an export compliance program and would like to   obtain some export compliance references to assist me and company colleagues.   What is the value of buying a hardcopy of the official regulations and   policies governing the export licensing of commodities and technical data?   Is it […]

  • EAR BEST PRACTICES

    Question: I am currently setting up an export compliance program and would like to obtain some export compliance references to assist me and company colleagues. what is the value of buying a hardcopy of the official regulations and policies governing the export licensing of commodities and technical data? Is it not best practice to use […]

  • Form BIS-645P applicability to USML and USMIL

      Question:   Could someone please comment if Supplement No. 5 To Part 748 – U.S. Import Certificate and Delivery Verification Procedure (a)(1)(iii) still needs to be corrected since DOS published a final rule April 17th, 2012 ceasing the DOS’s practice of accepting DSP–53 submissions (Amendment to the ITAR: International Import Certificate BIS–645P/ATF–4522/DSP–53 and Administrative […]

  • RISK FOR COURIER SHIPMENTS

      Question:   We sell all EAR99 products. For smaller export shipments, our company has   used couriers in the past. What are our risks in this approach? How do   couriers handle EEI filings?   **********

  • EAR99 FDA export restrictions to Afganistan

    Question: If we need to ship EAR99 medical/dental supplies to Afghanistan for use by US forces, are there any FDA export restrictions? (Examples: IV drip bag stands, metal scrapers, picks, etc. used in dental work, drip lines, plastic breathing tubes, fabric surgical drape cloths.) ============

  • Question on TMP Exemption

    Question:   If we  are not sure how a single signal generator was shipped to our parent company (maybe under a dsp 5, or no license under EAR) and it needs to be sent to US for repair,  are we allowed to  use the 123.4a.1 exemption under ITAR ?   Or are we only allowed […]

  • ACQUISITION LIABILITY

    Question: Our company just purchased the patents and assets of another company(they keep their tax id).  We are in the process of evaluating andclassifying their products for import/export, and they will begin usingour tax id’s for their limited import and export transactions as theyare migrated to our system, but I want to make sure I […]

  • EAR LICENSE EXCEPTION GOV

    Question: If something originally exported via license exception GOV and comesback for service/repair, does it ship back out under license exceptionGOV to the governmental agency or license exception RPL? Where in theEAR can I find this information?