Export Licensing

Question: Scenario: An item classified under ECCN 3A001.b.2. (NS1, NS2, RS1 controls) is destined to ship to Japan, which would require an export authorization. The customer in Japan confirms that the end-use is for a civil telecom application. License exception GBS can be used to ship items classified under ECCN 3A001.b.2. when they are exported/reexported […]

Question: If a staffing agency assigns one of their employees to a company on assignment and that employee requires an export license to view restricted technology in the USA based on their citizenship, who is responsible for obtaining the export license? The employer or the company who controls the technology and permits access to the […]

Question: Can you transship an export license order through an airport country/location where no license is required for the material? We have no other recourse than to ship freight through the connecting hub.  NO direct flights for the size of freight are available. Answer 1: Yes, you can but you should mention the transshipment on […]

Question: Our apologies – hoping 3rd time is a charm! Try again! Please note: This question went out yesterday, but the link to answer it was broken, it is fixed now. Thanks – ICPA Team Hi, Our US company is owned by an Italian company, due to several different circumstances our looking to bring 2-3 […]

QUESTION: Question: Company “A”  is importing an ECCN 9A120 agricultural drone from China. The drone is being imported into an FTZ and then exported out to Latin America. The item is never entered through Customs into the United States. Ordinarily if the drone is located in the US, it is subject to the EAR and […]

QUESTION: According to 15 CFR 772 and the SNAP-R User Manual, “The end user is not a forwarding agent.” I inherited oversight of a BIS technology export license to a foreign manufacturing site where a freight forwarder is listed as an end user.  Upon questioning this, I’ve learned that the freight forwarder is providing onsite, […]

QUESTION: We are a US non-profit organization that provide mainly EAR99 over-the-counter and prescription medicines and various medical supplies throughout the world. We have a 3PL in the NL that receive and warehouse a lot of our donated non-US medicines and medical supplies that we receive from our donors within Europe. The 3PL also provides […]

QUESTION: What is the process for replacing defective merchandise that requires an export license (BIS and DDTC) when you have shipped the full quantity or value allowed by the export license ? Is there a way to report the return and/or the destruction of defective goods and ship the replacement on the original license or […]

QUESTION: I have a question pertaining to these two headings in the CCL.  Both indicate “RS applies to the entire entry” and “A license is required for items controlled by this entry for export or reexport to Iraq or transfer within Iraq for regional stability reasons.  The Commerce Country Chart is not designed to determine […]

QUESTION: Is it a common practice to share the actual copy of an export license with a consignee listed on the license?  What reason could be used not to share the license and use a company letter stating the conditions and requesting an acknowledgement? ****************** Answers: Normally YES.  If there are specific provisos that pertain […]