We're back with Part III of our blog series in understanding “technology” controlled under the EAR. In Part I, we explored the concept of controlled technology. Then, in Part II, we examined the three different types of technology (“development,” “production,” and “use”) and how they are applied in practice. Now, in this Part III post, we’re examining what it means when an ECCN controls technology that is “required” for the development, production, or use of an item on the CCL (and also what it means when a control entry doesn’t include the defined term “required”).
Export control can be baffling to newcomers. It is a blizzard of acronyms, “defined terms,” and citations. In our compliance practice, we often have to lay out the basics for new clients in order to even discuss their situation. Many others know bits and pieces but don’t see how the puzzle fits together. So to any compliance veteran reading this, go no further. What follows is a primer, plain and simple.
Happy New Year, folks! I’ve kept you in suspense long enough, so here it is – Part II of our blog series in understanding “technology” controlled under the EAR.
“Quotation marks” are often misused. We have all read passages or seen “signs” where someone “clearly” didn’t realize what they were conveying with the “quotation marks.”
This may cross your mind when reading the Export Administration Regulations since there are many “words” in quotation marks which seemingly have no business being quoted. But you would be wrong. The use of quotations is deliberate and important, indicating that the quoted word or phrase should be reviewed under Section 772.1 – Definitions of terms as used in the EAR. Some are close to the definitions we typically associate with these words while others aren’t nearly as clear.
You’ve worked out your classification strategy and your budget. Now it’s time to prepare. What does that entail? What information is required to conduct a comprehensive, efficient and accurate export classification project? How should the data be organized? These are important questions that will affect the success and timeliness of this critical compliance initiative.
Topics: Commodity Classification