Export Licensing

Questions and answers about Export Licensing

  • Export License Requirement China/NP2

    Question: If a product (under 1C298) was made & exported from the US to an intercompany location in China years prior to China being added to NP2 controls in 2023, and now that intercompany Chinese location wishes to sell the 1C298 material to various (non-related) Chinese buyers, is a license required under NP2 controls? Items […]

  • Renewal of Expiring BIS Export License

    Question: Is there a process to renew an expiring BIS export license through SnapR or do we need to reapply again as for a brand new license application. Thanks Answer 1: Reapply for a new license but can reference the expiring one in the notes. Answer 2: Hi, you have to re-apply upon expiration.    […]

  • Noting

    Question: A customer in South America who buys our products FCA our US plant asks us to note: NLR no license required on our invoices. These are routed shipments, moved from the US by their forwarder.  My response is to decline this request, as it may constitute giving legal advice (they do not need a […]

  • License Exception – 740.17(b)(2)(i)(A)

    Question: There is an item that our company needs to ship from US to Saudi Arabia. According to the manufacturer, the item is classified as 5A002. The manufacturer claims that “this item is authorized for export under license exception ENC per the EAR Section 740.17(b)(2)(i)(A).  The subparagraphs (i)(A) fall under the (b)(2) designation.” Do we […]

  • ENC

    Question: We have a Juniper Router with ECCN 5A002.R that our company is planning to ship to Saudi Arabia. Is there a license exception -ENC -that can we apply? I checked the BIS website but I was unable to find that specific ECCN. Your feedback is much appreciated. Answer 1: I don’t remember if this […]

  • EU Export Licensing to Russia

    Question: Is the anyone in membership doing EU Export Licensing to Russia? If yes, are you experiencing long turnaround times? Say 6 months to a year or sometimes more? If no, what is your typical turnaround time? Answer 1: It depends which country you are exporting from the EU. I know BAFA in Germany is […]

  • Export License Requirement

    Question: I have a Dell BDR (Backup server) with an ECCN classification of 5A002 that needs to be shipped to Mexico. The Country of Origin is also Mexico would this item still require an export license to be exported or is there an exception for this? Answer 1: Your import of the server into MX […]

  • Export Licensing

    Question: We have a Bulk License that covers 9A610.x parts, accessories, attachments going to our parent company in Italy for various end-users also in Italy for a specific end item.  he license has two conditions, first is the normal condition regarding re-exporting, etc.  The second states the requirements of keeping records for each shipment containing, […]

  • foreign national employees

    Question: Although many Q&A regarding foreign nationals are in the database, I haven’t found anything specific for an upcoming scenario in my organization: We are a manufacturer in the aerospace industry and are owned by a foreign parent company.  We are looking to into a contract labor supplier that is working on setting up a […]

  • Russia Sanctions

    Question: Hello Membership! Does anyone ship medical devices to Russia and Belarus under an Export License?  I wonder if we can ship from US to a Distribution Center in EU without filing in AES and then ship from our DC in Europe who are listed as Intermediary consignee in a license? Thanks! Asked by: Irina […]