QUESTION: We currently do not indicate ECCN on our invoice for export shipments, the Customer is requesting ECCN on the Invoice. We are the USPPI and complete EEI filing with our designated Agent. ECCN and NLR is indicated on the EEI. Is the ECCN still required on Invoicing for export? ========== Answers: We do not […]
QUESTION: We are exporting a piece of equipment that contains a thermal imaging camera. The thermal imaging camera has an ECCN but because of its characteristics and to whom and to where we are shipping it, does not require a license. The equipment itself does not have an ECCN. How do I handle this from […]
QUESTION: Providing ECCN’s for domestic shipments when asked, however is it required to advise the ECCN’s to all domestic customers? Either by issuing a letter or by having the ECCN’s listed on all domestic shipment invoices? What is the best practice regarding ECCN’s for domestic shipments? =========== Answers: Best practice is to provide the ECCN of […]
QUESTION: Do any of the ICPA members have excel formatted lists of all ECCN’s and all USML’s down to the sub-paragraph details, along with descriptions, for use as “drop-down” choices in an internally developed ERP trade module, and are willing to share? %%%%%%%%%% ANSWERS: I do not, and such a thing would be exceedingly difficult […]
QUESTION: Is there a way to search for ECCN rulings, similar to the way that you can reference HTS binding rulings? ========== Answers: You can find advisory opinions: https://www.bis.doc.gov/index.php/policy-guidance/advisory-opinions. Also some companies list their ECCNs and related CCATS numbers online. It is voluntary though. https://www.bis.doc.gov/index.php/documents/licensing-forms/237-commodity-classification-information-1/file ========== No because they (CCATS) are not public, they are […]
QUESTION: Does anyone in the membership know what the correct ECCN is for Customer Support Services for encrypted hardware (5A002.a.1) & software (5D002.c.1) products? My interpretation of the regulations leads me to believe the ECCN for customer support services is 5E002(2) – When a person performs or provides technical assistance that incorporates, or otherwise draws […]
QUESTION: Does the last sentence “and parts, components, accessories and attachments specially designed therefor” refer to parts/components that are specially designed for the production equipment itself (then they are controlled under this ECCN) or are components that are could be manufactured by the production equipment (Then they are not controlled under this ECCN)? ========== Answers: […]
QUESTION: Our subsidiary in the UK recently went thru an audit with the Chamber of Commerce. One of the findings was aircraft cables purchased from the US having 2 different codes: 7312102500 (strand fitted w/fittings) and 8803300060 (parts of aircraft). The suggestion is to update our shared MRP system to reflect all aircraft cables exported […]
QUESTION: When doing an internal review, I noticed that some aircraft parts are declared as EAR99. Commodities represent a range of various products: from oil filters, batteries, aircraft body parts (doors, interior parts), wings to engines and complete (vintage) aircraft. All parts are for passenger (non-military) aircraft. Description for 9A991.d simply states: ““Parts” and “components,” […]
QUESTION: We have a component that is a standard catalog item that a customer has requested we modify for military vehicles. This vehicle is no longer on the USML. Would the classification for the component still be EAR99 or 0A606.y.9? ========== Answers: Hello, Some additional information could be very useful, like: What is the standard […]
QUESTION: I have an item that has an ECCN of 3A981, which is crime controlled. Destination is India. When I look on the Commerce Country Chart, there is no “x” on the CC1 column. Does that mean I can export the product and release technology to India without an US export license? ========== Answers: Correct. […]
QUESTION: I have challenges to make company’s software and make ECCN determinations, country of origin determination, and HTS#. 1) Does anyone have experience with software ECCN determination, templates, or guidance on how to make the determination? 2) Is SDK (software development kits) the same as software or different? 3) If a hardware has a software […]
