Question: We are an American company with international offices, and we greatly appreciate your support. Our office in India is currently developing software, and we are seeking guidance on whether it can be classified through the SNAP-R system, given that it is being developed outside of the United States. Your expertise in this matter would […]
Question: I’m trying to determine correct export controls that would apply to cryogenic pumps (LNG, liquid oxygen) that are used in space exploration applications. This type of pump is used to transfer gas from one place to another, and in regular, industrial applications (gas fueling stations, medical facilities, etc.) would be controlled under ECCN 2B999.j. […]
Question: We have a vaccine that was FDA approved under an EUA. Because it was EUA the ECCN was EAR99. however, the FDA has now fully approved the vaccine. If we export the vaccine, do we need to now use ECCN 1C.3661 (I think)? Answer 1: The 1C3661 ECCN does not exist. Uncertain as to […]
Question: What is the standard or best practice for ECCN declaration and determination to maintain as part of record retention period? Does this follow the same general rule under part 762.2 for export documentation? Also, if an ECCN declaration is outside of the five years, is this considered outdated and what would be the recommendation […]
Question: Can you please if there is master list of updated ECCN list you can download to add to ERP systems? I need to add to ERP system in order to build measures to flag and block non EAR99 items. Answer 1: You have to buy this from one of the trade software vendors. Answer […]
Question: Hello – We wanted to reach out and clarify some points regarding the distinction between source code controlled under ECCN 7D002 and software controlled under ECCN 7D994. To begin with, ECCN 7D002 specifically controls “Source code” for the operation or maintenance of any inertial navigation equipment. This includes inertial equipment not controlled by 7A003 […]
Question: Looking for the membership’s input on understanding 3A999 (a). A frequency changer has a maximum operating frequency of 1167Hz. Its operating frequency is between 0Hz and 1167Hz. Would this unit still be classified under 3A999(a) or not since the maximum is outside of this range? 3A999 a. Frequency changers capable of operating in the […]
Question: My understanding is that almost all medicines are considered EAR99 except for vaccines, “immunotoxins” (antibody-toxin conjugates intended to destroy specific target cells such as tumor cells that bear antigens homologous to the antibody), certain toxin containing medical products, and diagnostic and food testing kits are controlled under ECCN 1C991, 1C395, or 1C995. However, I’m […]
Question: Hi, This is a question for all the SAP users out there. We have ShipErp “bolt on” to our SAP platform, but I am told that ShipErp DOES NOT support the info needed for exporting very well. i.e. schedule B#, ECCNs, etc. I am finding this out the hard way. Does anyone in the […]
Question: Our organization had to send server to update our IT system to EU. The server falls under 5a992 c.. There is and AT control but NLR to Poland. Do I need to limit access to the server by anyone who could be citizen of N.Korea, Syria, Iran, Cuba etc. (if any)? Would this be […]
Question: If a dual-use valve is incorporated into another item, for example a pump, is the pump now considered controlled as dual use? Answer 1: EAR 770.2(b) addresses your question. As a general rule in the EAR, an assembled item is classified in the form in which it is exported, regardless of the classifications of […]
Question: So I want to submit a classification request to BIS for a finished overhead scale. I know I have to send details of components. What is the Membership’s experience with finished items vs some of the individual items that may appear on the control list? Example: This scale has a loadcell and maybe other […]
