Question: Case Scenario: ECCN 3A611.x parts are exported by a domestic US company to a military contractor (company “A” in country “X’) on a BIS license for integration into a Non-ITAR foreign Defense article. That item is re-exported to a company “B” in country “Y”. Company “B” in country “Y” is not on the export […]
Question: If we apply for a replacement export license with BIS, does that application immediately “void out” the original license? I have a situation where I need to add an intermediate consignee in a 3rd country and obtain a replacement export license for a client that has a license to export machinery parts to Russia. […]
Question: Hello Membership! I have the following scenario for which I’m hoping for some advice. We are the importer/exporter of medical devices for clinical trials. In 2017 our company exported a shipment of medical devices from the U.S. to Russia for a clinical trial before the sanctions. The sponsor in Russia has completed the trial […]
Question: Dear Membership, Regarding extraterritorial jurisdiction of the EAR, is there any guidance from BIS concerning the definition of “U.S. origin” as stated in 734.2(a)(2)? A foreign manufacturer procures a US-origin raw material from their US affiliate (the exporter). This foreign manufacturer uses this raw material to produce a commodity that qualifies as foreign origin […]
Question: Our company has STC (Supplementary Type Certificate) documentation that the FAA provides to foreign agencies for airworthiness approval/certification. Within the STC package is controlled technical data (ECCN 3E611) that requires a license to be exported. The FAA does not allow the controlled technical data to be removed or redacted. Personnel I’ve chatted with at […]
Question: We have a European made monoclonal antibody (drug substance in bulk, not a finished good) that has more than 10% US content. It is not related to any virus, nothing on the Australia list. Neither the MAB nor its CAS are listed in the CCL. It is sent to Russia for further manufacture into […]
Question: Looking for guidance regarding interpretations Part 770.2 and licensing requirements: My company manufactures civil aircraft. We install navigation and vertical reference system equipment. These radio/transceivers are ‘600’ series items. Part 770.2 interpretation states ‘parts of machinery, equipment or other items physically incorporated into the machine, equipment or other item do not need a license’. […]
Question: We are purchasing a radar from the OEM in Italy, that under US regulation would be considered ITAR. I would like to ship this radar direct from the OEM to the US Embassy in Tunisia. Can this be done without authorization from the US Government, or does the ITAR require us to bring the […]
Question: In their consolidated licensing guide DECCS has a list of definitions for their status indicators. Is there a similar list for the ELISA status indicators? They do not appear to be all the same terms used in both sites. Tia. Answer 1: I’m not sure what you mean by “indicators”. ELISA simply shows the […]
Question: Our company exported servers as EAR99 to multiple countries. I recently discovered the ECCN is 5A992c. Can someone outline the steps I need to take to understand the EAR requirements for this ECCN / Country combination? Then I assume we will need to get expert assistance with how to correct any EAR violations. Thanks. […]
Question: Our company is planning to move some items from US to Saudi Arabia. These items are classified under ECCN# 1A995, 2B999, 2B999.j, 3A002.a, 3A992.a, 3A999.a, and 5A991d. I checked the Country Chart and the CCL list and what I understand is that the ONLY item that will need an export license is the item […]
Question: We have product that shipped on a DSP-73, because of the Air Embargoes on Somalia, we will have to move the freight in via ocean. Our license expires in 3 weeks, what is the best way to request an extension to the current license? Asked by: Wendy Cunningham – wendy.cunningham@mag.us Answer 1: The DDTC […]
