Question: We are evaluating whether the license exception TMP (‘Tools of Trade’) under 15 CFR 740.9 can be applied to an export classified under NP2. Has anyone confirmed its applicability in this context, and are there specific conditions or limitations we should be aware of? Answer 1: In general, Nuclear Proliferation (NP) controls do not […]
Question: Dear Members. In the license exception RPL, at 740.10 (b)(2)(iii), the language states “imported from Country Group D:1 except the People’s Republic of China (PRC)”. Is this stating that items imported from China, even though legally exported there, are not eligible for RPL? This same exception language is also stated in (b)(3)(ii)(B). OR is […]
Question: A US company procures equipment with ECCN 5A002 from an unrelated UK company. The equipment will ship from the UK to the US company’s locations in China. The UK company will ship using their OIEL export license. Is a license or license exception also required from the US side? Answer 1: Your shipment will […]
Question: Hello, I’m currently exploring certifications in export control to strengthen my skills and support my work. I’m considering the ECoP EAR and ITAR certifications, as they seem to be well recognized in the industry. I’ve been working in Export Control and have built some experience and knowledge in this area, but I’d like to […]
Question: Hello, I’m currently exploring certifications in export control to strengthen my skills and support my work. I’m considering the ECoP EAR and ITAR certifications, as they seem to be well recognized in the industry. I’ve been working in Export Control and have built some experience and knowledge in this area, but I’d like to […]
Question: Provided that there are no end-user/end-use concerns, please confirm my understanding of EAR licensing requirements is correct for export/re-export of foreign-made items to Russia/Belarus: Scenario 1: Foreign-made EAR99 item comprised of US and non-US EAR99 components, not a direct product of dual-use US technology – No License Required to export/re-export to RU/BY Scenario 2: […]
Question: Hello Members! We manufacture a machine that can cut anything from ice cream cakes to airplane parts. I have been asked to approve an end user that manufactures military weapons. The machine itself is not specifically designed for military use, but it can be used to cut materials used in manufacturing weapons, military items, […]
Question: Hello, Members I submitted an export license application about a month ago. A few days after I submitted, I noticed that there was some information missing in the application. Knowing that modification is not possible through SNAP-R, I send a ‘Request to RWA’ via email (snapr@bis.doc.gov). I expected (and hoped) that they would confirm […]
Question: Hello – We are seeking to benchmark with other companies regarding License Exception GBS and the verbiage in the exception that states: “License Exception GBS authorizes exports and reexports to Country Group B, except Sudan and Ukraine, of those commodities where the Commerce Country Chart indicates a license requirement to the ultimate destination for national […]
Question: Hello All, Would steel samples require an export license if shipping from US to Israel? Samples to be tested for armor plate use. Thank you! Answer 1: Any personnel involved in exports should be familiar with the EAR. I cannot tell you without specific information regarding your item instead I encourage you to look […]
Question: Case Scenario: ECCN 3A611.x parts are exported by a domestic US company to a military contractor (company “A” in country “X’) on a BIS license for integration into a Non-ITAR foreign Defense article. That item is re-exported to a company “B” in country “Y”. Company “B” in country “Y” is not on the export […]
Question: If we apply for a replacement export license with BIS, does that application immediately “void out” the original license? I have a situation where I need to add an intermediate consignee in a 3rd country and obtain a replacement export license for a client that has a license to export machinery parts to Russia. […]
