Exporters Use with Caution: Online Decision Tree Tools

June 25, 2013
By Jim Trubits

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tablettrapMuch has been written about forthcoming U.S. export control reforms and the impact it will have on exporters. Many exporters hoped these reforms would make the export control process easier by limiting it to the authority of one government agency, the Department of Commerce.

Unfortunately, one can gather from recently published changes that the one agency idea has been pushed aside to make room for further complexity and additional requirements.

The recent changes consist of moving certain military aircraft parts from the U.S. Munitions List to the Commerce Control List and creating a new 600 series of Export Control Classification Number (ECCN) referred to as specially designed. This new 600 series applies to any ECCN in which 6 is the third character (e.g. ECCN 9A610).

Exporters that fall under these provisions will need to take additional steps to ensure their complete compliance when filing their Electronic Export Information in AES and completing their export documentation.

With a nod towards making these changes more user friendly, the Bureau of Industry and Security has developed two online decision tools to guide exporters in understanding and applying the specially designed definition and strategic trade authorization license exception.

NOTE: The strategic trade authorization license exception was implemented on June 16, 2011 (15 CFR § 740.12). It will also apply to “600” series items starting October 15, 2013.

These decision tree tools provide key terminology look ups for users, including links to the relevant sections of the Export Administration Regulations.

Should you choose to self-classify using these tools, it’s best to rely on an engineer. When in doubt, seek a classification decision from the Bureau of Industry and Security.

Jim Trubits is Director of Business Development for Mohawk Global Logistics.

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