News & Noteworthy

Heightened Scrutiny for "Emerging" Technologies

Posted by Chalinee Tinaves on Nov 21, 2018 8:41:37 AM
This week the Bureau of Industry and Security (BIS) published an advance notice of proposed rulemaking (ANPRM) seeking comments from the public on criteria for identifying “emerging technologies” essential to U.S. national security. As part of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (NDAA), the Export Control Reform Act of 2018 (ECRA) authorized the Department of Commerce to establish appropriate controls for exports of “emerging and foundational technologies.” However, at the time, what was covered under this phrase was not clear. BIS took a step forward this week by identifying several technology sectors of concern. 
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Topics: BIS, Export Compliance, Technology

Exporting to Hong Kong? Don't Be Caught Flat Footed Come April 19

Posted by Chalinee Tinaves on Apr 4, 2017 1:36:07 PM

Starting April 19, 2017, U.S. companies and persons intending to export or reexport certain items subject to the Export Administration Regulations (EAR) to Hong Kong should make sure you’ve got your import paperwork in order before shipping. Not familiar with this requirement? In the hubbub of the inauguration and other news, this final rule published in the Federal Register on January 19 by the Bureau of Industry and Security (BIS) at the U.S. Department of Commerce may have slipped past you.

Under the final rule, exporters and reexporters of certain items to Hong Kong are required to obtain a copy of a valid import license from the Hong Kong importer issued by the government of Hong Kong or a copy of a written statement issued by the Hong Kong government that no import license is required. The requirement also applies to persons intending to reexport certain items from Hong Kong. While this shouldn't be news for importers and reexporters in Hong Kong, the BIS requirement to obtain written proof from their Hong Kong importers prior to shipment is new.

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Topics: BIS, Export Control Regulations, Country Guidance

Harmonizing the Destination Control Statement: What You Need to Know

Posted by Chalinee Tinaves on Aug 25, 2016 12:00:00 PM

On August 17, 2016, the Bureau of Industry and Security and the Department of State published final rules (here and here) to harmonize the Destination Control Statement (DCS) required under §758.6 of the Export Administration Regulations (EAR) and §123.9 under the International Traffic in Arms Regulations (ITAR) respectively. As part of Export Control Reform (ECR) efforts, the agencies have sought to harmonize regulatory provisions that are intended to achieve the same purpose. The DCS is one example of an area where interagency coordination should reduce the burden on exporters.

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Topics: DDTC, BIS, Export Compliance

The ABCs of the CCL: Spotlight on Parts and Components

Posted by Bruce Webb on Jun 21, 2016 10:30:00 AM

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.

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Topics: BIS, Commodity Classification

The ABCs of the CCL: New Series on Commodity Classification

Posted by Bruce Webb on Jun 14, 2016 10:30:00 AM

Want the Commerce Control List (CCL) made clear? Need faster, easier classifications? You’re in the right place. Industry veteran Bruce Webb will be offering tips here in his CTP blog to help you understand the basics of commodity classification, adapt to changes, and unravel the gnarly terminology of commodity classification using the CCL. Over to you Bruce.

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Topics: BIS, Export Compliance, Commodity Classification