ITAR & EAR Export Compliance

What is EAR99 and how does it affect my export?

An EAR99 designation is reached after an item, data, or service is not found to be export controlled under the US Munitions List (USML) or the Commerce Control List (CCL).  The EAR99 classification means that the item, data, or service will not need any approvals or export under a special exemption or exception to leave…

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How to determine export approval requirements for an ECCN under the CCL?

An item, technology, or service associated with an Export Control Classification Number (ECCN) under the Commerce Control List (CCL) may need export approval depending on the reasons for control.  The process of determining and evaluating the reasons for control may be a bit cumbersome but can be found on the BIS website under Commerce Control…

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Which Organizations Control Commerce and Defense Trades?

The US Commerce Department regulates non-defense related exports governed by the Export Administration Regulations (EAR) under the Commerce Control List (CCL). The US State Department – Directorate Defense Trade Controls (DDTC) regulates defense-related exports governed by the International Traffic in Arms Regulations (ITAR) under the US Munitions List (USML). The order-of-review requires that evaluation of…

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Do I need an export license to export?

Determining export jurisdiction and classification is a process called the order-of-review.  An article, technical data, or service is first evaluated against the US Munitions List (USML) under the International Traffic in Arms Regulations (ITAR) then, if not under the USML, it is evaluated against the Commerce Control List (CCL) under the Export Administration Regulations (EAR).…

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Does Defense Trade Controls Worry About the Import of Defense Articles?

Not really – this is controlled by U.S. Customs, so if they approve the article for import, you have satisfied the requirements. Defense Trade Controls gets involved when you want to export that article back to the original provider or to somewhere else.

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