ITAR Export Compliance

EAR99 is a classification for an item. It indicates that a particular item is subject to the Export Administration Regulations (EAR), but not listed with a specific Export Control Classification Number (ECCN) on the Commerce Control List (CCL). While the classification describes the item, the authorization for shipment of that item may change, depending on…

An item may be licensable if it has been assigned a specific Export Commodity Control Number (ECCN) by the Commerce Department and is dependent upon an item’s technical characteristics, destination country, end-user, and the intended end-use.

The US Commerce Department regulates non-defense related exports governed by the Export Administration Regulations (EAR). The US State Department – Directorate Defense Trade Controls (DDTC) regulates defense-related exports governed by the International Traffic in Arms Regulations (ITAR). Commerce Department export website: http://www.export.gov/ | Defense Trade Controls website: http://www.pmddtc.state.gov/

A Commodity Jurisdiction Request (CJR) can be submitted to determine if a defense export license is required. Basically, articles that are defense-related or will be used for defense purposes are “ITAR controlled” and will require a license. It is always easier and safer to get the license for a defense export rather than suffer the…

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.