Question: Our company has STC (Supplementary Type Certificate) documentation that the FAA provides to foreign agencies for airworthiness approval/certification. Within the STC package is controlled technical data (ECCN 3E611) that requires a license to be exported. The FAA does not allow the controlled technical data to be removed or redacted. Personnel I’ve chatted with at […]
Question: We have a European made monoclonal antibody (drug substance in bulk, not a finished good) that has more than 10% US content. It is not related to any virus, nothing on the Australia list. Neither the MAB nor its CAS are listed in the CCL. It is sent to Russia for further manufacture into […]
Question: Looking for guidance regarding interpretations Part 770.2 and licensing requirements: My company manufactures civil aircraft. We install navigation and vertical reference system equipment. These radio/transceivers are ‘600’ series items. Part 770.2 interpretation states ‘parts of machinery, equipment or other items physically incorporated into the machine, equipment or other item do not need a license’. […]
Question: We are purchasing a radar from the OEM in Italy, that under US regulation would be considered ITAR. I would like to ship this radar direct from the OEM to the US Embassy in Tunisia. Can this be done without authorization from the US Government, or does the ITAR require us to bring the […]
Question: In their consolidated licensing guide DECCS has a list of definitions for their status indicators. Is there a similar list for the ELISA status indicators? They do not appear to be all the same terms used in both sites. Tia. Answer 1: I’m not sure what you mean by “indicators”. ELISA simply shows the […]
Question: Our company exported servers as EAR99 to multiple countries. I recently discovered the ECCN is 5A992c. Can someone outline the steps I need to take to understand the EAR requirements for this ECCN / Country combination? Then I assume we will need to get expert assistance with how to correct any EAR violations. Thanks. […]
Question: Our company is planning to move some items from US to Saudi Arabia. These items are classified under ECCN# 1A995, 2B999, 2B999.j, 3A002.a, 3A992.a, 3A999.a, and 5A991d. I checked the Country Chart and the CCL list and what I understand is that the ONLY item that will need an export license is the item […]
Question: We have product that shipped on a DSP-73, because of the Air Embargoes on Somalia, we will have to move the freight in via ocean. Our license expires in 3 weeks, what is the best way to request an extension to the current license? Asked by: Wendy Cunningham – wendy.cunningham@mag.us Answer 1: The DDTC […]
Question: Is there a “POD” requirement for commodities exported using an export license or license exception? Answer 1: No. Obviously if the carrier or someone makes you aware of loss/diversion, you may want to look into it, but the base answer remains NO. Answer 2: It is best practice to verify proof of delivery but […]
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 […]
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. […]
Question: We obtained an export license approved by BIS, however a few of the items approved have changed their unit value very significantly, thus exceeds the one approved on the license. Has anyone on the membership have had this happened and how do you handle it? Is there a method to ask BIS to amend […]
