Question: When classifying items with a schedule b #, should it be done by what the raw material is or what the item is used for? Thank you Answer 1: Classification of goods under the Schedule B Harmonized System follows the same General Rules of Interpretation (GRIs) and Additional U.S. Rules of Interpretation as found […]
Question: All, Does anyone have experience sending antiquities back to their original county? We have some items they were excavated in the early 1980’s. We now want to return these items. Part of the issue is some items have ivory in them. We are getting mixed information about exporting. I thought they could be sent […]
Question: Please help me classify item NAVS500, Wireless HD Video Digital Transmitter & Receiver. Which classification will work best and why? 8517.62.0020 or 8525.503040. Answer 1: This seems to be a “machine” that is “designed for the purpose of performing two or more complementary or alternative functions”. You need to perform a “principal function” analysis […]
Question: Hello, We are currently procuring some parts and components from Romania, and they want to send those to us under military license, although our use is completely commercial, as they say those fall under ML10. I am actually not familiar with EU regulations and I don’t know how this will affect the Export Classification […]
Question: Is 9E619.a and 9A619.a eligible for STA? Shipping a part to Sweden and would like to use STA if possible. Answer 1: Directly from the EAR, Supplement No. 1 to Part 774 – The Commerce Control List Under 9A619: List Based License Exceptions (See Part 740 for a Description of All License Exceptions) LVS: $1,500 GBS: N/A Special […]
Question: We generally use HTS codes for export, but one of our codes is no longer accepted in AES. Does anyone have advice on interpreting the breakdown of 8517.62.0030 – 8517.62.0080? Our technical folks are getting hung up on thinking that multiprotocol can only include the three options before it (Wifi, Bluetooth and proprietary). Do […]
Question: Looking for documented support/justification (regulatory, SMEs, best practices) for why Trade Compliance uses the more stringent classification in a situation like the stack of drawings with varying ECCNs, such as EAR99 and 3A611.x, to be sent to a supplier. The end use is to provide technology needed to design/develop a machine which will be […]
Question: We have containers that we ship back empty to our suppliers that they use to fill and send us our parts back into the US. Currently we are not claiming chapter 9801 on the import side. For exports I am currently using the classification of the containers. My question is since ownership does not […]
Question: Can you please advise if parts, components, accessories and attachments to the J69 engine is still under the jurisdiction of ITAR? Or if this is part of the Export Reform that’s been migrated from ITAR to EAR? Asked by: Brenda Lumagui – blumagui@aeroturbineinc.com Answer 1: First, we have to know how much power the […]
Question: There is this statement in paragraph (h) of Cat VIII: h) Parts, components, accessories, attachments, associated equipment and systems, as follows: (1) Parts, components, accessories, and attachments specially designed for the following U.S.-origin aircraft: The B-1B, B-2, B-21, F-15SE, F/A-18 E/F, EA-18G, F-22, F-35, and future variants thereof; or the F-117 or U.S. Government […]
Question: Is it accurate to say that Controlled Unclassified Information (“CUI”) in US DOD speak translates to SOME export control classification under either the EAR or ITAR (e.g. could be EAR99, any ECCN or any USML)? So all CUI is subject to export regulation. Answer 1: CUI and U.S. export-controlled information overlap like a Venn […]
Question: how would ICPA classification experts classify a crankcase for an air compressor? would there be an ECCN or would EAR99 suffice? Answer 1: There is not enough information to give an accurate answer. The HTS is probably in 8414. The ECCN for the crankcase will be determined by the ECCN for the complete compressor […]
