Question: Here’s the background: I got a new job at a software company. Currently reviewing all their ECCNs. They farmed out the self-classification and SNAP-R to a third party on one of their products recently. The third party pitched BIS a 5D002 (b)(2) on that product. BIS ruled accordingly – we got (b)(2). The product […]
Question: My company wants to export a list of 248 Â commercial, off-the-shelf small electrical parts (i.e. resistors, diodes, capacitors, etc.) to a third party in Thailand who will be assembling all the parts and returning finished goods to our company here in the US. If we are not claiming any Free Trade status for this […]
I am looking for help classifying radar. I have not been able to get enough information from the manufacturer to qualify or disqualify the radar from 6A008. I’m hoping someone has experience and could advise. We think there is likely an easy way to say this does fit under 6A008, but don’t understand the technology […]
Question: When members classify their products for exports with an ECCN and store the classifications in their database of record, do they have the need to include sub ECCN breakdowns? If so, is the sub ECCN used in any sort of export control process (either manual or automated)? Any examples of how far you have […]
Question: We manufacture electronic equipment that we have designated as EAR99. However, recently I was informed that some of our products with this designation contain MMIC power amplifiers. Do we need to make a classification determination based on the MMIC amplifier within the final product, or the final product performance and technical characteristics itself? ========== […]
Question: Our company sells software coding services (i.e. software developers in a room writing code), is that “service” considered a product? There may be an opportunity for our company to export that service (e.g. our US workers’ brains travelling to Canada to write code or our company’s newly written code developed in the US being […]
Question: I have a basic question about ECCN’s and controls under the CCL. It is my understanding that the Commerce Control List is designed to control the export and re-export of domestic (USA) items/technologies. 1. Does that mean the CCL really only applies to US origin goods and/or goods developed using US origin technology/engineering, etc.? […]
Question: I remember hearing about a penalty case where a manufacturer gave an incorrect ECCN to their customer, the customer exported with that ECCN and the manufacturer was penalized. I want to include this in our ECCN training but cannot find the case. Can the membership share a case reference number or link? ********* Answers: […]
Question: We have a project that is in the R&D phase. I am greatly in need of membership feedback. Lets say that we have 1 apple, 1 banana, 1 pear, 1 plum. All are of equal importance and together they make a fruit salad – without equal parts of all 4 fruits, you do not […]
Question: I’m in the process of determining the ECCN for a list of biometric devices that are used in one of our facilities. We have fingerprint, iris and facial scanners as well as mobile scanners that are a combination fingerprint/iris scanner, none of which are manufactured by my company. I’ve found fingerprint scanners listed on […]
Question: If you are not the manufacturer of the items but mostly purchase spare parts and machinery to be exported to your manufacturing plants, how do you validate the ECCN of the items do you self classify or do ask the supplier, etc..? ==========
Question: If a commercial aircraft bearing doesn’t meet the ECCN criteria for 2A001, 2A101 or 2A991 etc. and would otherwise be classified EAR99. Does the fact that the bearing is used specifically on aircraft cause the bearing to be classified under 9A991.d – d. Aircraft parts and components, n.e.s. if it doesn’t the more stringent […]
