QUESTION: Our company comprises multiple divisions that have been recently acquired. When they were stand-alone companies, our divisions had their own trade compliance policies and procedures. But we are now in the process of harmonizing these trade compliance policies and procedures under a common corporate model. One specific issue where we currently have multiple, inconsistent […]
QUESTION: Is proprietary information that is not within the scope of the definition of technology subject to the EAR? In other words, we have determined that information in a document does not meet the definition of technology IAW EAR 772.1, however the information is still protected as proprietary. Is this proprietary information subject to the […]
QUESTION: “We are a commercial company (not registered with DDTC, not producing defense articles or services), most of our products are EAR99 because of general applicability (math, computational, simulation software). Our customers use our products for wide range of applications from education to defense related applications. One of the defense applications is EW (electronic warfare), […]
QUESTION: Does the government (or other credible source) publish a list of EAR-controlled items at highest risk of illegal diversion? I’m constructing a risk profile for my organization and want to consider the types of commodities we export as a factor in that analysis. Please note we only sell EAR-controlled items (some under specific ECCNs, […]
QUESTION: We make, sell domestically and export product that is EAR99 and not on the CCL. We received a request from a foreign customer to include the DCS statement on our commercial invoices. EAR99 product not on CCL are not subject to the DCS requirement. Are we creating any liability by including this statement on […]
QUESTION: Under https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear When pressing the GPO’s EAR: e-CFR, https://www.ecfr.gov/cgi-bin/text-idx?gp=&SID=02b534f76f96c9c5f13a1d1be8edf8d4&mc=true&tpl=/ecfrbrowse/Title15/15CVIIsubchapC.tpl, pressing 774, https://www.ecfr.gov/cgi-bin/text-idx?SID=94ecdb1389dc924dcc12efe2cc9de1f3&mc=true&node=pt15.2.774&rgn=div5, the following message appears: The requested document does not exist. It may have been moved to a different volume. You can try browsing to the document from here. Or under https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear, when pressing the CCL on the e-CFR, https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=02b534f76f96c9c5f13a1d1be8edf8d4&ty=HTML&h=L&n=15y2.1.3.4.45&r=PART, the same message appears: […]
QUESTION: Under https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear When pressing the GPO’s EAR: e-CFR, https://www.ecfr.gov/cgi-bin/text-idx?gp=&SID=02b534f76f96c9c5f13a1d1be8edf8d4&mc=true&tpl=/ecfrbrowse/Title15/15CVIIsubchapC.tpl, pressing 774, https://www.ecfr.gov/cgi-bin/text-idx?SID=94ecdb1389dc924dcc12efe2cc9de1f3&mc=true&node=pt15.2.774&rgn=div5, the following message appears: The requested document does not exist. It may have been moved to a different volume. You can try browsing to the document from here. Or under https://www.bis.doc.gov/index.php/regulations/export-administration-regulations-ear, when pressing the CCL on the e-CFR, https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=1&SID=02b534f76f96c9c5f13a1d1be8edf8d4&ty=HTML&h=L&n=15y2.1.3.4.45&r=PART, the same message appears: […]
QUESTION: My company is looking to update the templates for our export docs, which currently have the pre-2016 version (15 CFR 758.6) of the Destination Control Statement. We ship non-haz recyclable materials, and everything is EAR99, so I believe this was included as a “just in case” for future business. We have noticed all our […]
QUESTION: Our U.S. designed products are sold out of the U.S. and the U.K. In accordance with U.S. Export Control Reform, we have reclassified many of our formerly ITAR controlled products to EAR control. Some have transitioned to 600-series ECCN’s and some have transitioned even to a less-restrictive ECCN. Some dual use products were already […]
QUESTION: Do any of the members remember where we can find the cross reference to all CAS#s in the Commerce Control List? I have searched the EAR and cannot find this tool. *********** Answers: Under the CCL, the CAS number are in many cases written inside, so do a simple search (Ctrl-F) under the CCL […]
QUESTION: I’m an American Company and buy a lot of goods from British Company. Not nuclear, but definitely energy sector. Would be considered EAR99. British Company might be doing business in Iran, totally legal for them. If they are selling their goods to Iran, can I continue to do business with British Company? Or because […]
QUESTION: Scenario- domestic sale of a EAR99 item to a OEM company. The OEM is combining with other products and selling to a “Government job” that will be a export. It is not told to us at the time of shipment that this will be sold for export. The only way we found out is […]
