Compliance practitioners know that commodity classifications are the essential first step in determining export control requirements, responsibilities and risks. However, in situations where the exporter is not the original manufacturer of an item or specific product specifications are unavailable, making an export classification determination can be difficult. One valuable and often overlooked piece of information is the National Stock Number (NSN) but it must be used with caution.
The Paris Air Show is the largest and most famous Air and Space Exposition worldwide and the 2017 version at Le Bourget airport did not disappoint the huge crowds that braved the blistering heat. From a historical perspective, it was the 90th anniversary of Lindbergh’s 33 hour solo flight from New York to Paris, a route that commercial passenger jets routinely fly now in 7 hours. In these 90 years, aviation technology has advanced at near lightning speed and the Paris Air Show is the world showcase of aviation technology, a stage for a myriad of companies—from the huge aerospace conglomerates to the small, innovative startups—to display their latest innovations. Every other year, Boeing, Airbus, GE, Honeywell and dozens of other U.S. companies and foreign competitors introduce their newest technologies here. Among the 2017 highlights:
CTP’s renowned expert, Bruce Webb, pens a semi-regular blog on the nuances of commodity classification. Visit our archive for past entries by Bruce and other CTP experts.
I want to discuss recent experiences involving the ITAR exemptions for UK, Australia and Canada. Why these specific nations? Because these country-specific ITAR exemptions are made possible through existing country-to-country agreements as well as treaties relating to defense trade. These arrangements allow for the export of specific defense articles and defense services which meet the strict requirements set forth for each but this is not a carte blanche to export freely. Each transaction must be reviewed to avoid misinterpretation.
Unsure about the intricacies of commodity classification? Well, you’re in luck since our expert, Bruce Webb, is preparing a series of blogs to demystify the Commerce Control List. This is the second of our series and focuses on “Parts and Components.” Take it away Bruce.
Hello again everyone. When classifying items under the Export Administration Regulations (EAR), the phrase “Parts and Components” consistently appears in the various Export Control Classification Number (ECCN) entries on the Commerce Control List (CCL). Although they appear to identify the same things, these two terms have very specific and separate meanings defined in Part 772.1 of the EAR.