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. […]
Question: Hello Membership! I have the following scenario for which I’m hoping for some advice. We are the importer/exporter of medical devices for clinical trials. In 2017 our company exported a shipment of medical devices from the U.S. to Russia for a clinical trial before the sanctions. The sponsor in Russia has completed the trial […]
Question: Dear Membership, Regarding extraterritorial jurisdiction of the EAR, is there any guidance from BIS concerning the definition of “U.S. origin” as stated in 734.2(a)(2)? A foreign manufacturer procures a US-origin raw material from their US affiliate (the exporter). This foreign manufacturer uses this raw material to produce a commodity that qualifies as foreign origin […]
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 […]
