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
Commodity classification is critical. In fact, we call it Job #1 since most of your compliance requirements are based on these determinations. But classification projects are not all the same. Most companies use the “surge” approach, tackling the entire inventory all at once, be it dozens, hundreds or thousands of items. Other companies, for various reasons, can’t process everything at once and must rely instead on the “flow” method of classifying items only when they enter the Order Processing system. Both are valid and effective methods, giving companies the licensing requirements they need, but to help you pick your strategy, we’ll walk you through the pros and cons of wholesale “surge” classification versus the “flow-through” basis.