When it comes to EAR compliance, a common mistake is to find the Export Control Classification Number (ECCN) for your product and then make all your licensing determinations based on that alone. However, it’s important to remember there are actually two ECCNs for every item – one that controls the product, and a second that…
ITAR compliance is agreeably difficult, and exemptions are not “exempt” from this conundrum. Take, for example, the export of defense articles and technical data. When you export articles and technical data to support that article, they are considered completely separate items and require a separate authorization under the ITAR regulations. This rule is a bit…
Many clients are surprised when they start working on their export policy by the amount of flexibility there is – particularly when it comes to how they comply with the regulations. This most often occurs during the development or improvement of a company’s export compliance procedures. The basic goals of ITAR and EAR are relatively…
We get a lot of questions from clients about what to do if they use suppliers who are not registered with DDTC to perform ITAR-related work. This presents an interesting dilemma. Although it’s clear that the supplier is violating Section 122.1 of the ITAR, is the company who sends that supplier ITAR-controlled work also violating…
Understanding Codes For International Trade Many trade compliance departments are faced with the decision to assign both a Schedule B Number and a Harmonized Tariff Schedule (HTS) code to their products, or just to assign the HTS code only. The Harmonized System of classification is a six-digit standard for classifying globally traded products. The first…
The BIS recently published a list of seven new “best practices” to help companies improve their export trade compliance. Specifically, these best practices are designed to help avoid the diversion of dual-use items at international transshipment points (or “hubs”). Here are the seven best practices. It seems that this list comes up short on practical, real-world advice…