QUESTION: What are some of the best practices is the group using to review ECCNs subject to MEU for China, Russia, and Venezuela? Is anyone using 3rd party reports to identify red flags for end users in these countries? =========== Answers: Yes, we have a form that we use to provide guidance on what we […]
QUESTION: I need assistance with assigning an ECCN to a kit/assembly. Half of our team is of the belief that the ECCN should be based on the technical characteristics of the end-product. Example- shipping components (some assembled, some not) in one box and assigning the ECCN based on the characteristics of the product once assembled, […]
QUESTION: Do I understand correctly that for a pump classifiable under ECCN# 0A998.b.3, a part shipped separately (e.g. body casting) would not itself be classifiable under ECCN# 0A998.b.3 rather that would be EAR99? Also, for a part to be classifiable under an ECCN it would need to be specifically called out, for example in ECCN […]
OT Fact Sheet: Origin Certification Requirements QUESTION: I’m guessing I know the answer already, but true or false . . .there is no good translation from UNSPSC codes to ECCN or USML. United Nations Standard Products and Services Codes (UNSPSC) ****************** Answers: No direct translation. As an aside, there was an effort in a […]
OT Fact Sheet: Origin Certification Requirements QUESTION: We currently do not indicate ECCN on our invoice for export shipments, the Customer is requesting ECCN on the Invoice. We are the USPPI and complete EEI filing with our designated Agent. ECCN and NLR is indicated on the EEI. Is the ECCN still required on Invoicing for […]
QUESTION: We currently do not indicate ECCN on our invoice for export shipments, the Customer is requesting ECCN on the Invoice. We are the USPPI and complete EEI filing with our designated Agent. ECCN and NLR is indicated on the EEI. Is the ECCN still required on Invoicing for export? ========== Answers: We do not […]
QUESTION: We are exporting a piece of equipment that contains a thermal imaging camera. The thermal imaging camera has an ECCN but because of its characteristics and to whom and to where we are shipping it, does not require a license. The equipment itself does not have an ECCN. How do I handle this from […]
QUESTION: Providing ECCN’s for domestic shipments when asked, however is it required to advise the ECCN’s to all domestic customers? Either by issuing a letter or by having the ECCN’s listed on all domestic shipment invoices? What is the best practice regarding ECCN’s for domestic shipments? =========== Answers: Best practice is to provide the ECCN of […]
QUESTION: Do any of the ICPA members have excel formatted lists of all ECCN’s and all USML’s down to the sub-paragraph details, along with descriptions, for use as “drop-down” choices in an internally developed ERP trade module, and are willing to share? %%%%%%%%%% ANSWERS: I do not, and such a thing would be exceedingly difficult […]
QUESTION: Is there a way to search for ECCN rulings, similar to the way that you can reference HTS binding rulings? ========== Answers: You can find advisory opinions: https://www.bis.doc.gov/index.php/policy-guidance/advisory-opinions. Also some companies list their ECCNs and related CCATS numbers online. It is voluntary though. https://www.bis.doc.gov/index.php/documents/licensing-forms/237-commodity-classification-information-1/file ========== No because they (CCATS) are not public, they are […]
QUESTION: Does anyone in the membership know what the correct ECCN is for Customer Support Services for encrypted hardware (5A002.a.1) & software (5D002.c.1) products? My interpretation of the regulations leads me to believe the ECCN for customer support services is 5E002(2) – When a person performs or provides technical assistance that incorporates, or otherwise draws […]
QUESTION: Does the last sentence “and parts, components, accessories and attachments specially designed therefor” refer to parts/components that are specially designed for the production equipment itself (then they are controlled under this ECCN) or are components that are could be manufactured by the production equipment (Then they are not controlled under this ECCN)? ========== Answers: […]
