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 […]
Question: Our company is involved with downloads of software from different servers located worldwide and some time will purchase software from vendors shelf will purchase shelf products. Our group is responsible in verifying and assigning ECCN for the software components of the application. Recently encountered a third party vendor that provided ECCN 5D992.b.1. […]
Question: Our company is involved with downloads of software from different servers located worldwide and some time will purchase software from vendors shelf will purchase shelf products. Our group is responsible in verifying and assigning ECCN for the software components of the application. Recently encountered a third party vendor that provided ECCN 5D992.b.1. so […]
Question: I have a CNC PC based machine tool controller software, motion controller card, microsystem computer loaded with CNC program for a lathe, the lathe was exported under ECCN 2B991. My question is would the ECCN for all the items be 2B991 or each of the items have a different ECCN. ************
Question:I’ve been tasked to come up with a “simple” way for our Engineering Department to assist me in determining ECCN’s. While I understand this is not a simple task, I’m wondering if anyone has a checklist or other document that would point me in the right direction. Most of our products fall in Category 5 […]
Question: My company manufactures products that generally would be EAR99, howeverbecause they are specially designed they fall under the classification of theupper level assembly. Our components are manufactured metal components withmachined metal ends. We manufacture in the US and the company would like touse offshore machine houses. My questions are how far down the supply […]
Question:I have been told that wire ties or zip ties are controlled for U.S. export – I’m assuming under ECCN 0A982. Does anyone else export these items and classify them as controlled, other than EAR99?
Question: We received a one-time review for encryption software for telecom equipment (ECCN :5D002c.1) The cd’s that contain the software also contain user guides and Administrator’s guides that describes how to administer and use the telecom equipment, No encryption information is included in the user guides. These documents are shipped with the […]
if the 3A001 EPROMS are embedded into a CPU board and 5D992 software hasbeen loaded onto the CPU board – we have been classifying the boards as5A992 and the final product as 5A992; software 5D992 and disregarding the3A001 – is this correct? We also looked into 4A994 and were told that 5A992 trumps…and I pickedcompliance […]
My company currently exports ERPOM’s loaded with software. When classifying the ECCN, should I be classifying the EPROM or the software? Also, does anyone know if EPROM’s are typically controlled for export? I have looked into 3A001a.2. and 3A001.a.4.
We export digital computers / servers and their APP is .102 WT (weighted TeraFLOPS) and I would like some help in whether it is classified in 4A003 or 4A994. Any help would be appreciated feel free to contact me directly via email or phone.
