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 […]
QUESTION: One of our ITAR/EAR-controlled facilities is sharing office space with a sister company foreign national employees. The employees have access to our facility and share our break room and restroom areas. There is no outside entrance upstairs, so the employees have to access yellow line only areas to get to there work area. What […]
QUESTION: Does anyone know if there’s a recent annotated EAR? I have one for ITAR and FTR but haven’t found a recent one for EAR. ========== Answers: Not sure what you mean by “annotated”. The “live”, current version with all updates is always at the ecfr site: https://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&tpl=%2Findex.tpl ========== https://www.ecfr.gov/cgi-bin/text-idx?node=pt22.1.121 ========== I personally have never […]
QUESTION: There is a company on the Entity List, and we want to sell some EAR99 goods (nothing listed in 15 CFR 746.5’s ECCNs or HTS numbers) to them in Vietnam, but the bank involved is refusing to process the funds. The bank tells me that they cannot tell me why they refused the transaction […]
QUESTION: We have a current customer that wants to be a Distributor is Russia. Since Russia has many sanctioned individuals, I want to ensure we are in compliance and have done our due diligence . The items they will be purchasing are not controlled under EAR or ITAR. We screen all our customers, vendors, […]
QUESTION: According to EAR 742.8, it appears EAR99 items are allowed to export to Iran if the end use or end user is not mentioned in the regulation or found as a restricted party. In addition to, if the commodity is not noted in Part 746.7. However, I am not too sure about OFAC 560.201.205? […]
QUESTION: We recently received the commodity classification result from the BIS for our NEW software that will be used for our devices. The result is ECCN EAR99 which basically means we are now free to do anything with the software, except sending them to the US embargoed countries. The OLD software was previously classified by […]
QUESTION: If items subject to the EAR are exported to Country A and then subsequently re-exported to Country B, is the re-exporter required to include the Destination Control Statement on their export paperwork? ========== Answers: If the items are U.S. origin, yes. Do companies overseas adhere to it? Most likely not, but I am seeing […]
