Question: We produce various auto accessories that customers may purchase individually, or sometimes we package multiple items together into “sets” or “kits”. These items do not build a complete finished goods, merely co-pack items that will be used together on a vehicle. These items are EAR99/NLR. One customer in Latin America has requested that we […]
Question: Hello, What is the process to become a USPPI / Exporter? Thanks. Answer 1: In any export transaction, the party that is considered the “economic beneficiary” is always consider the USPPI of the transaction. As the USSPI, export control responsibility will always default to your company, unless it is a routed transaction involving a […]
Question: Would EAR99 medicine and medical devices need a license to export to NGO’s in Belarus for humanitarian purposes? Answer 1: We manufacture and export medical devices. I have not found any exceptions or general licenses available to use for exports to Belarus. I too would be interested in any responses received. Answer 2: The […]
Question: We manufacturer Plastic Returnable packaging (EAR99) for a variety of parts. Typically customers will send CAD drawings to us for us to develop a solution. We are running into customers that have Export Controls on their CAD Drawings and we are now trying to figure out what best practice looks like and how we […]
Question: I am the TCO based in the US with responsibility globally (and local tco’s in other countries we manufacture in) Our recently acquired Canadian manufacturing company is attracting a lot of interest in the US and in particular the defense area. Our customers are asking us to provide export classifications for products purchased. I […]
QUESTION: My company regularly exports from the US military aircraft parts and components via truck for repair to Canada. The parts and components are controlled under BIS. A most recent shipment heading outbound to Canada sent under ECCN 9A610.x NLR has been detained for the last 3 weeks by US Customs (Detroit/Windsor) and they will […]
QUESTION: We have PMA on ballscrew assemblies that were originally produced for a very large US airplane manufacturer. We now sell to USAF for the E-3 AWACS and would like to know if we send blanks to an Italian supplier for machining, would this would fall under the 600 series or 9A991.d, the plane was […]
QUESTION: Being new to exports, I would like to ask a question for clarification. An AES filing is required if the aggregate HTS number on the invoice is over $2500. What if there are other items (HTS) on the invoice that do not go over the $2500? Is the AES filing strictly for the HTS […]
QUESTION: In a true routed export scenario: US manufacturer ships to the FPPI’s named US forwarder for export. The US manufacturer’s commercial document shows the sold-to (FPPI) and the ship-to (US Forwarder). Who is responsible for creating the actual export invoice when the goods ship from the US? The USPPI- using the above-mentioned commercial invoice […]
QUESTION: Pending export transaction involving medical equipment to Cuba. Fully understand that an EAR/BIS license is required and that in most cases BIS approves licenses for medical devices/equipment: Question: Is an OFAC license also required? Based on some prior Cuba licensing I did several years ago, I think the answer is NO only an EAR/BIS […]
QUESTION: We are trying to put forth a questionnaire to our internal business unit to determine whether the machine learning software, programs, libraries, and technology we are working on are export controlled. Can the membership share your best practices on what to ask of the internal business unit(s) in regards to machine learning? What questions […]
QUESTION: We are an integrator and IT set-up provider for companies across the globe. In several instances the companies who we do this for have sourced and supplied their own equipment. We have always operated under the understanding they have to be the EOR if it is being exported as we don’t own the goods. […]
