Questions and answers about Export

  • Export Controlled Data How to manage

    Question: We manufacturer Plastic Returnable packaging (EAR99) for a variety of parts. Typically customers will send CAD drawings to us for us to develop a solution.  We are running into customers that have Export Controls on their CAD Drawings and we are now trying to figure out what best practice looks like and how we […]

  • Canada Export Control Classifications

    Question: I am the TCO based in the US with responsibility globally (and local tco’s in other countries we manufacture in) Our recently acquired Canadian manufacturing company is attracting a lot of interest in the US and in particular the defense area.  Our customers are asking us to provide export classifications for products purchased.  I […]


    QUESTION: My company regularly exports from the US military aircraft parts and components via truck for repair to Canada.  The parts and components are controlled under BIS.  A most recent shipment heading outbound to Canada sent under ECCN 9A610.x NLR has been detained for the last 3 weeks by US Customs (Detroit/Windsor) and they will […]


    QUESTION: We have PMA on ballscrew assemblies that were originally produced for a very large US airplane manufacturer. We now sell to USAF for the E-3 AWACS and would like to know if we send blanks to an Italian supplier for machining, would this would fall under the 600 series or 9A991.d, the plane was […]

  • Export question

    QUESTION: Being new to exports, I would like to ask a question for clarification. An AES filing is required if the aggregate HTS number on the invoice is over $2500.  What if there are other items (HTS) on the invoice that do not go over the $2500?  Is the AES filing strictly for the HTS […]


    QUESTION: In a true routed export scenario: US manufacturer ships to the FPPI’s named US forwarder for export. The US manufacturer’s commercial document shows the sold-to (FPPI) and the ship-to (US Forwarder). Who is responsible for creating the actual export invoice when the goods ship from the US? The USPPI- using the above-mentioned commercial invoice […]


    QUESTION: Pending export transaction involving medical equipment to Cuba. Fully understand that an EAR/BIS license is required and that in most cases BIS approves licenses for medical devices/equipment: Question: Is an OFAC license also required? Based on some prior Cuba licensing I did several years ago, I think the answer is NO only an EAR/BIS […]


    QUESTION: We are trying to put forth a questionnaire to our internal business unit to determine whether the machine learning software, programs, libraries, and technology we are working on are export controlled. Can the membership share your best practices on what to ask of the internal business unit(s) in regards to machine learning? What questions […]

  • Exporting while not owning Goods

    QUESTION: We are an integrator and IT set-up provider for companies across the globe. In several instances the companies who we do this for have sourced and supplied their own equipment. We have always operated under the understanding they have to be the EOR if it is being exported as we don’t own the goods. […]


    QUESTION: Under a routed export scenario foreign buyer instructs U.S. supplier to ship a part to their freight forwarder using Free Carriage (FCA) Incoterm. Supplier/Seller arranges domestic shipment to Miami. Under FCA seller has responsibility for customs clearance and documentation. Does the USPPI (or their authorized agent) have to request written authorization/POA from Foreign Principal […]


    QUESTION: My organization is currently screening our export orders / shipments against our Restricted Party Screening application.  Many of our foreign customers are actual distributors, so we know they are not the End user.  Some of our distributors are a related party and others are not.  The concern for the non-related distributors is to release […]

  • Parties to a BIS Licensed Transaction + Routed Export Scenario

    QUESTION: Scenario: Company A in USA handles the sourcing and purchasing of ECCN 1C234 zirconium metals on behalf of Company B in China. Company B is a marketing office based in Hong Kong that is also sole owner of Company C a smelting plant that melts the Zirconium material and produces a commercial product out […]