Question: Hello fellow trade nerds,We applied for an export license, received the license and shipped the product. However, when time came to service the product we found out that that the named customer on the License, while retaining ownership, has allowed a project partner (a different company) to use the product. This “sharing” of licensed […]
Question: If you export a shipment under a DSP-5 license and the EEI was submitted and the license decremented, but when the shipment arrived to the destination country and it was return because the customer didn’t clear customs. Can we cancel the EEI and reuse the license? or do we need to get a new […]
Question: I have an friend who’s company has pending Commerce license applications for ECCN 3B991 (AT1 controls), product to export to China. The applications not been processed for over a year and just prior to their one year anniversary were briefly reviewed by State/DoD and closed out. Direct emails to BIS enquiring on status go […]
Question: How long does it typically take to get a response to a license application submitted via SNAP-R? weeks, months, etc.we have submitted a few license applications for shipments of 1C350 material to a few different nations, and want to be able to give updates to the end users on status. Answer 1: it depends […]
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: Yes, you do […]
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: 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 […]
