QUESTION: I am working a classification initiative for syntarian control – Synturian Control has been recently tested with two Group 1 UAS (between 0-20 lbs, maximum speed of 100 kts). These are some general data points: Control can be used for any and every unmanned platform…tractors, boats, rotary wing, fixed wing, submarine. Currently we have […]
QUESTION: Can the membership please comment on how their organizations have structured the task of classifying EAR controlled unpopulated printed circuit boards (PCB) for export? We have seen two methods used but have a difficult time finding definitive guidance. An example would be a finished PCB with an ECCN of 5A991 with the only control […]
Question: I am curious as to whether anyone has more information on how BIS may define “High Pressure Pumps” under 0A998.b.3. I can’t find any sort of GPM or PSI that I can use to gauge whether a pump is considered “High Pressure” or not and would love to hear from the membership if […]
Question: We are a manufacturing company that has both domestic and international customers. Some domestic customers are asking us to provide the HTS and ECCN for our entire product line. We have given these on a case- by- case basis, with an appropriate disclosure that the information provided is based on our knowledge, but it […]
Question: Here’s the background: I got a new job at a software company. Currently reviewing all their ECCNs. They farmed out the self-classification and SNAP-R to a third party on one of their products recently. The third party pitched BIS a 5D002 (b)(2) on that product. BIS ruled accordingly – we got (b)(2). The product […]
Question: My company wants to export a list of 248 Â commercial, off-the-shelf small electrical parts (i.e. resistors, diodes, capacitors, etc.) to a third party in Thailand who will be assembling all the parts and returning finished goods to our company here in the US. If we are not claiming any Free Trade status for this […]
I am looking for help classifying radar. I have not been able to get enough information from the manufacturer to qualify or disqualify the radar from 6A008. I’m hoping someone has experience and could advise. We think there is likely an easy way to say this does fit under 6A008, but don’t understand the technology […]
Question: When members classify their products for exports with an ECCN and store the classifications in their database of record, do they have the need to include sub ECCN breakdowns? If so, is the sub ECCN used in any sort of export control process (either manual or automated)? Any examples of how far you have […]
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 sells software coding services (i.e. software developers in a room writing code), is that “service” considered a product? There may be an opportunity for our company to export that service (e.g. our US workers’ brains travelling to Canada to write code or our company’s newly written code developed in the US being […]
Question: I have a basic question about ECCN’s and controls under the CCL. It is my understanding that the Commerce Control List is designed to control the export and re-export of domestic (USA) items/technologies. 1. Does that mean the CCL really only applies to US origin goods and/or goods developed using US origin technology/engineering, etc.? […]
Question: I remember hearing about a penalty case where a manufacturer gave an incorrect ECCN to their customer, the customer exported with that ECCN and the manufacturer was penalized. I want to include this in our ECCN training but cannot find the case. Can the membership share a case reference number or link? ********* Answers: […]
