Category: Other Import/Export

One of the lesser-understood rules in the Export Administration Regulations (EAR), is the de minimis rule, which determines whether foreign-made products that incorporate U.S.-controlled content are subject to the EAR. While making international trade easier and better defining the jurisdiction and classification of items, the Export Control Reform (ECR) Initiative has also complicated the application...

Looking for someone to conduct a gap analysis of your trade compliance activities? Consultants come in all shapes and sizes, with various backgrounds, skills and expertise. But not all consultants (or their assessments) are created equal! Before you give that consultant a green light, make sure you have a thorough understanding of what they'll be...

Very often, we talk with individuals who are focused on specific needs. They have questions like: “How do I get an ITAR license?” or “What is the ECCN for my product?” Although these questions are valid and important, sometimes companies need to take a step back and look at the bigger picture. Instead of focusing...

You may find your customers asking if your products qualify for NAFTA or if you can provide a NAFTA certificate. The logical questions that follow are: “What is NAFTA?” and “What is a NAFTA certificate?” In this blog, we’ll provide a basic overview of NAFTA in order to help with your understanding of this topic....

Have you ever been frustrated or stymied by those DoD Distribution Statements concerning Critical Technology, which appear to prohibit U.S. contractors from sharing the data with their partners in Canada? If so, you’re not alone! Well, there is a way to work within the framework of our country’s special relationship with Canada, via the United...

Savings and more savings on duties and fees are available for exporters who import their U.S. goods back into the United States. These savings are not BOGO (buy one, get one). Rather, they are for all U.S. goods returned (and some Non-U.S. goods). Have you ever reviewed Chapter 98 of the Harmonized Tariff Schedule? If...

“Did you hear? The Cuban sanctions have been lifted! I can’t wait to go on a vacation and bring back some cigars.” Whoa! Not so fast there, buddy. With the recent announcements from the Department of the Treasury, Office of Foreign Assets Control (OFAC), concerning the amendments to the Cuban Assets Control Regulations (CACR) to...

Roses are red, violets are blue, Have you read BIS’ “Don’t Let This Happen to You?” Violations, penalties, debarments and more Somebody out there has to keep score. From a CEO attempting exports to Iran, To encrypted technologies released in Sudan. Every case brings a fine or some time spent in jail Every company must...

With the ringing in of 2015, I’m sure many of you have made some resolutions. For those of us in the trade compliance field, updating our classification matrices is certainly one of them. While we were busy ushering in the New Year, U.S. Customs and Border Protection (CBP) and the U.S. Department of Census were...

In my last blog article, we examined the Specially Designed Decision Tool. Today, we will explore the new “Catch and Release” concept when determining if a product meets the definition of “Specially Designed.” First, here is the definition in the current ITAR. [My Notes will be in brackets, boldface, and Italics. All underlines are my...