Export

Question: How would others interpret the verbiage contained in this sanction? The United States government shall not issue any specific license and shall not grant any other specific permission or authority to export any goods or technology to “x” under  the Export Administration Act of 1979 (50 U.S.C. Appx. 2401;  the Arms Export Control Act […]

Question: Is there an event that would drive the following statement to be included on documentation for goods departing the US and heading to Australia:   THESE GOODS ARE NEW GOODS NOT USED GOODS AND HAVE NOT BEEN FIELD TESTED And then signed by the CEO of the company?  For some reason we have this […]

Question: Does the 72 hour export rule apply to self-propelled underground construction equipment (i.e. a tired drill, excavator, wheel loader). ========== Answer: Any used self-propelled vehicles as described in 19 CFR 192.1 fall under the 72 hour advance reporting/presentation requirements.  This includes construction equipment.  If your products are classified under HTS/Schedule B’s shown in bold […]

Question: We are looking to implement an electronic record keeping policy for our export shipments similar to our current electronic record keeping policy for imports.  Is there even the possibility of electronic record keeping for export documents.  If so, which agency do we request from and what are the regulations? ************** ANSWERS: See the EAR […]

Question: Please note we have been notified by our Europe location that our product has to start filing SASO and Letter of Conformity immediately.   We have been shipping our USA manufactured products to Saudi Arabia for years and have a distributor under contract there. I am questioning this requirement for our product. I cannot find […]

Question: Every year we request the EEI report from Census to complete our internal auditing of export shipments. This year we received a larger number of Routed shipments than in previous years. Since most of our exports are standard, not routed shipments and we would like to get more information on these routed shipments to […]

Question: We have a machine which contains approximately 500 components for assembly for production in Mexico.  In the past, the assembly occurred in the US but the company is looking to export the components to Mexico for assembly.   I understand Mexico also allows for the option to import a disassembled machine and classify it as […]

Question: If a shipment to a customer’s selected freight forwarder would not require an EEI filing due to one of the filing exemptions, is this still a routed export? (The item is only subject to the EAR, not ITAR.) What are the USPPI’s responsibilities in this situation? Do we still send the routed export letter […]

Question: What is the general stance of BIS and 14nm technology?  We normally file our licenses and deemed export licenses to include technology in line with the ITRS roadmap.  Up until now, we have always had 18nm technology explained in our LOE and it was accepted.  Can I expect any issue on 14nm? ************ Answers: […]

Question: Do other members require an export POA for their forwarding agents?  I have always operated that tendering the BOL acts as the right to file AES and act as the designated forwarding agent on my companies behalf.  I would like to hear how others operate. ***************** We do use export POAs as we control […]

Question: In the below drop ship scenario is there any filing or documentation that needs to be submitted to US government. Company A – US Exporter Company B – Customer in Asia Company C – Vendor in Asia Company B places order with Company A. Instead of shipping direct to customer we have our vendor […]