Question: Is there a “POD” requirement for commodities exported using an export license or license exception? Answer 1: No. Obviously if the carrier or someone makes you aware of loss/diversion, you may want to look into it, but the base answer remains NO. Answer 2: It is best practice to verify proof of delivery but […]
Question: If a product (under 1C298) was made & exported from the US to an intercompany location in China years prior to China being added to NP2 controls in 2023, and now that intercompany Chinese location wishes to sell the 1C298 material to various (non-related) Chinese buyers, is a license required under NP2 controls? Items […]
Question: Is there a process to renew an expiring BIS export license through SnapR or do we need to reapply again as for a brand new license application. Thanks Answer 1: Reapply for a new license but can reference the expiring one in the notes. Answer 2: Hi, you have to re-apply upon expiration. […]
Question: We obtained an export license approved by BIS, however a few of the items approved have changed their unit value very significantly, thus exceeds the one approved on the license. Has anyone on the membership have had this happened and how do you handle it? Is there a method to ask BIS to amend […]
Question: A customer in South America who buys our products FCA our US plant asks us to note: NLR no license required on our invoices. These are routed shipments, moved from the US by their forwarder. My response is to decline this request, as it may constitute giving legal advice (they do not need a […]
Question: There is an item that our company needs to ship from US to Saudi Arabia. According to the manufacturer, the item is classified as 5A002. The manufacturer claims that “this item is authorized for export under license exception ENC per the EAR Section 740.17(b)(2)(i)(A). The subparagraphs (i)(A) fall under the (b)(2) designation.” Do we […]
Question: We have a Juniper Router with ECCN 5A002.R that our company is planning to ship to Saudi Arabia. Is there a license exception -ENC -that can we apply? I checked the BIS website but I was unable to find that specific ECCN. Your feedback is much appreciated. Answer 1: I don’t remember if this […]
Question: Is the anyone in membership doing EU Export Licensing to Russia? If yes, are you experiencing long turnaround times? Say 6 months to a year or sometimes more? If no, what is your typical turnaround time? Answer 1: It depends which country you are exporting from the EU. I know BAFA in Germany is […]
Question: I have a Dell BDR (Backup server) with an ECCN classification of 5A002 that needs to be shipped to Mexico. The Country of Origin is also Mexico would this item still require an export license to be exported or is there an exception for this? Answer 1: Your import of the server into MX […]
Question: Hi, I work for a US company that has a location in Germany. We are purchasing some dual-use parts from a UK OEM, who is shipping them via an OGEL to Germany. Do I need to apply for a Commerce license to store them there, or just apply for a license for each sale […]
Question: We have a Bulk License that covers 9A610.x parts, accessories, attachments going to our parent company in Italy for various end-users also in Italy for a specific end item. he license has two conditions, first is the normal condition regarding re-exporting, etc. The second states the requirements of keeping records for each shipment containing, […]
Question: Although many Q&A regarding foreign nationals are in the database, I haven’t found anything specific for an upcoming scenario in my organization: We are a manufacturer in the aerospace industry and are owned by a foreign parent company. We are looking to into a contract labor supplier that is working on setting up a […]
