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: […]
Question: We have a project that is in the R&D phase. I am greatly in need of membership feedback. Lets say that we have 1 apple, 1 banana, 1 pear, 1 plum. All are of equal importance and together they make a fruit salad – without equal parts of all 4 fruits, you do not […]
Question: I’m in the process of determining the ECCN for a list of biometric devices that are used in one of our facilities. We have fingerprint, iris and facial scanners as well as mobile scanners that are a combination fingerprint/iris scanner, none of which are manufactured by my company. I’ve found fingerprint scanners listed on […]
Question: If you are not the manufacturer of the items but mostly purchase spare parts and machinery to be exported to your manufacturing plants, how do you validate the ECCN of the items do you self classify or do ask the supplier, etc..? ==========
Question: If a commercial aircraft bearing doesn’t meet the ECCN criteria for 2A001, 2A101 or 2A991 etc. and would otherwise be classified EAR99. Does the fact that the bearing is used specifically on aircraft cause the bearing to be classified under 9A991.d – d. Aircraft parts and components, n.e.s. if it doesn’t the more stringent […]
Question: A company acts as the US export agent for several FPPIs who purchase their products from an US seller and have them shipped to the US agent’s warehouse. Some of the products are consumer electronics and may be controlled under EAR. When the US agent contacts the US seller to verify if the item […]
Question: I was wondering if any of the members have experience with exporting potassium nitrate? I am not finding any mention of it in the EAR. Any suggestions you have would be much appreciated. Thank you. ==========
QUESTION: If a configurable electronic instrument has been classified as 4A994 by BIS, are we required to use 4A994 when we ship a component separately, such as for a spare part or upgrade purpose? The component shipped separately might be a p c board, cable, led or lcd display, etc. *************
Question: Are requests for Commodity Classification by the BIS, both paper and SNAP-R, confidential? Are they available through the FOIA ============
Question: During an audit we have discovered several ECCN shipments that were filed with C33 rather than C32, although the ECCNs in question are controlled for more than Anti-Terrorism (AT). I am trying to get a scope of how far back I need to follow this – can the membership please advise when […]
Question: We export an item under an ECCN in CCL Category 3 that requires a license to the destination country. The ECCN has a specific performance threshold that must be achieved. A few months later the item is returned to us for repair or replacement, which would be eligible for RPL treatment. But […]
