Export Licensing

Questions and answers about Export Licensing

  • Russia Sanctions

    Question: Hello Membership! Does anyone ship medical devices to Russia and Belarus under an Export License?  I wonder if we can ship from US to a Distribution Center in EU without filing in AES and then ship from our DC in Europe who are listed as Intermediary consignee in a license? Thanks! Asked by: Irina […]

  • Export controls on helmets

    Question: Has anyone had athletic helmets get caught up in ECCN 0A979?  Specifically, helmets intended for inline skating and winter sports?  0A979 is pretty vague, saying only, “Police helmets and shields; and ‘specially designed’ ‘components,’ n.e.s.”  The List of Items Controlled says only, “The list of items controlled is contained in the ECCN heading.” Answer […]

  • Export license to Russia

    Question: My company, which manufactures medical devices, submitted two Export license applications for Russia (based on HTS inclusion in new EAR Supplement No. 4 to Part 746) in early August 2023, and according to STELA they are still showing as pending.  I provide daily updates to the business leaders based on what I see in […]

  • SNAP-R expor license status

    Question: Hi everyone, I submitted an application for export license in SNAP-R and it is under “Pending” status. Is there a way to know which licensing officer has been assigned to the case while it is under interagency review? I’d like to contact the officer appointed to the case.  Thank you. Answer 1: You will […]

  • Social Media posts, Export Controls, and LK99

    Question: I’ve been searching for real world examples of “Do’s” and “Don’ts” for an export control training.  The trainees are a group of researchers.  Does the membership think that a scenario like the LK-99 social media posts could apply?  Assuming the claims are real, it would be groundbreaking – Can the membership help me with […]

  • SNAP-R

    Question: I’ve recently requested to open a SNAP-R account but been told by BIS that there are some IT issues preventing them from opening the account, and that “it should be fixed soon”.  This is for a one-off export of a machine that requires a license.  Has anyone else had the same experience?  Any other […]

  • Foreign National license for customer

    Question: My customer has an export authorization that allows their foreign national employee to work on a specific project that concerns products classified as 9A###. Does this authorization cover my company sharing controlled technical data with this employee or do I need my own authorization? Answer 1: Assuming the export authorization is a BIS license, […]

  • BIS Licensing

    Question: Are there different BIS Licensing requirements for goods that will be permanently exported vs. goods that are being exported for rental and will be returned to the US? Answer 1: The requirements are the same, however, depending on the circumstances, there are some available BIS license exceptions that can apply in certain circumstances (e.g. […]

  • Export license from EU

    Question: Can anyone share a list of requirements to apply for an export license from EU? If license exception is available, what info. need to be added on invoice? Asked by: AMI MEHTA – ami.mehta@teradyne.com Answer 1: Hello, It depends on the country; each have their own application and rules – which country are you […]

  • License Exception GBS Scenario

    Question: Scenario: An item classified under ECCN 3A001.b.2. (NS1, NS2, RS1 controls) is destined to ship to Japan, which would require an export authorization. The customer in Japan confirms that the end-use is for a civil telecom application. License exception GBS can be used to ship items classified under ECCN 3A001.b.2. when they are exported/reexported […]

  • Deemed Export License for contractors

    Question: If a staffing agency assigns one of their employees to a company on assignment and that employee requires an export license to view restricted technology in the USA based on their citizenship, who is responsible for obtaining the export license? The employer or the company who controls the technology and permits access to the […]

  • Trans shipment

    Question: Can you transship an export license order through an airport country/location where no license is required for the material? We have no other recourse than to ship freight through the connecting hub.  NO direct flights for the size of freight are available. Answer 1: Yes, you can but you should mention the transshipment on […]