QUESTION: Our subsidiary in the UK recently went thru an audit with the Chamber of Commerce. One of the findings was aircraft cables purchased from the US having 2 different codes: 7312102500 (strand fitted w/fittings) and 8803300060 (parts of aircraft). The suggestion is to update our shared MRP system to reflect all aircraft cables exported […]
QUESTION: When doing an internal review, I noticed that some aircraft parts are declared as EAR99. Commodities represent a range of various products: from oil filters, batteries, aircraft body parts (doors, interior parts), wings to engines and complete (vintage) aircraft. All parts are for passenger (non-military) aircraft. Description for 9A991.d simply states: ““Parts” and “components,” […]
QUESTION: We have a component that is a standard catalog item that a customer has requested we modify for military vehicles. This vehicle is no longer on the USML. Would the classification for the component still be EAR99 or 0A606.y.9? ========== Answers: Hello, Some additional information could be very useful, like: What is the standard […]
QUESTION: I have an item that has an ECCN of 3A981, which is crime controlled. Destination is India. When I look on the Commerce Country Chart, there is no “x” on the CC1 column. Does that mean I can export the product and release technology to India without an US export license? ========== Answers: Correct. […]
QUESTION: I have challenges to make company’s software and make ECCN determinations, country of origin determination, and HTS#. 1) Does anyone have experience with software ECCN determination, templates, or guidance on how to make the determination? 2) Is SDK (software development kits) the same as software or different? 3) If a hardware has a software […]
QUESTION: We are currently looking into our new technology that is coming out soon and have questions on license determination. If we have WIFI or voice controls on our finished goods, could this change our ECCN from EAR99 possibly to 3a001 or other classification? We do not export these as parts but are included in […]
QUESTION: I would like to know if anyone has similar experience classifying for a SSL certificate that is used to generated an encryption for a web server? If you can share your ECCN, that will be create ******** Answers: See the related controls note in 5D002 which states that once mass market encryption eligibility requirements […]
QUESTION: To define the ECCN for Valves that we use for Oil and Gas Production, will it still be under 2B350.g, IF it is NOT intentionally designed for use in Chemical Manufacturing Equipment? We would appreciate if we could get deeper insights into this. ========== Answers: No. You need to analyze the materials […]
QUESTION: Does anyone have insight as to what the BIS position is on the scope of 2B999.f .g and .n? Do the valves have to be entirely made of Monel or 304/316SS or austenitic SS? Does it only control valves whose wetted parts (surfaces that come in direct contact with the media) are made of […]
QUESTION: I am working a classification initiative for syntarian control – Synturian Control has been recently tested with two Group 1 UAS (between 0-20 lbs, maximum speed of 100 kts). These are some general data points: Control can be used for any and every unmanned platform…tractors, boats, rotary wing, fixed wing, submarine. Currently we have […]
QUESTION: Can the membership please comment on how their organizations have structured the task of classifying EAR controlled unpopulated printed circuit boards (PCB) for export? We have seen two methods used but have a difficult time finding definitive guidance. An example would be a finished PCB with an ECCN of 5A991 with the only control […]
Question: I am curious as to whether anyone has more information on how BIS may define “High Pressure Pumps” under 0A998.b.3. I can’t find any sort of GPM or PSI that I can use to gauge whether a pump is considered “High Pressure” or not and would love to hear from the membership if […]
