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.
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.