ITAR & EAR Export Compliance

An EAR99 designation is reached after an item, data, or service is not found to be export controlled under the US Munitions List (USML) or the Commerce Control List (CCL).  The EAR99 classification means that the item, data, or service will not need any approvals or export under a special exemption or exception to leave…

An item, technology, or service associated with an Export Control Classification Number (ECCN) under the Commerce Control List (CCL) may need export approval depending on the reasons for control.  The process of determining and evaluating the reasons for control may be a bit cumbersome but can be found on the BIS website under Commerce Control…

Determining export jurisdiction and classification is a process called the order-of-review.  An article, technical data, or service is first evaluated against the US Munitions List (USML) under the International Traffic in Arms Regulations (ITAR) then, if not under the USML, it is evaluated against the Commerce Control List (CCL) under the Export Administration Regulations (EAR).…

Not really – this is controlled by U.S. Customs, so if they approve the article for import, you have satisfied the requirements. Defense Trade Controls gets involved when you want to export that article back to the original provider or to somewhere else.

A defense export license basically covers items like hardware, software, and data and consist of a few different types – permanent export, temporary export, temporary import, etc. Agreements cover assistance to a foreign nation on a given defense subject and fall into two categories – Technical Assistance Agreement (TAA) and Manufacturing License Agreements (MLA). Give…