Definitions
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Etymologies
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Examples
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"Flash can also maintain and control the number of parts shipped under a client's specific ECCN license; this helps clients determine license quantities that are becoming low, or are close to expiration."
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• Research the Commerce Control List to check the reasons for export control; • Look at the "Reason For Control" section directly under the ECCN category heading and License Requirements; • Example; Reason for control NS, MT, AT • Match specific controls to the Country Chart column in the EAR Copyright 2004-2008 James G. Shaw III cscp 26
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More Rules To Know About • General Prohibitions 1 through 3 apply only if the item is classified under a specific ECCN • Prohibition 1 applies to the Export and re - Export of controlled items to listed countries • Prohibition 2 applies to re-Export and Export from abroad of foreign-made items incorporating more than a de minimis amount of controlled U.S.
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Establishing the ECCN • Identify and confirm the major characteristics of the item with the ECCN listing and review all sub-paragraphs • "The devil is in the details" so do this carefully and do not rush this portion of the identification process • Select the final, most applicable characters to finalize the ECCN Number Copyright 2004-2008 James G. Shaw III cscp
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• An exception is a provision identified in the EAR ECCN with very specific conditions that must be applied to enable the use of an Export License Exception Code on the Export Documentation Copyright
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The Commerce Control List • This lists items that are subject to licensing under the authority of the Bureau of Industry and Security (BIS) • Each Export Control Classification Number (ECCN) is a 5 (or more) character string that is alpha-numeric.
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Classify The Product • The "Commerce Control List" is the cornerstone • The items must receive a clear determination of the EXPORT CONTROL CLASSIFICATION NUMBER • Commonly referred to as the "ECCN" Number • This Number Directs Further Activities Copyright 2004-2008 James G. Shaw III cscp 6
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The Commerce Control List • PRODUCT GROUPS • Identified in the second (alpha) character in the ECCN number: • A Equipment, Assemblies and Components • B Production, Test and Inspection Equipment • C Materials (raw) - See Following Pages for Product Groups Copyright 2004-2008
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More Rules To Know About • The General Prohibitions should also be applied to avoid "self blinding" (also known as "looking the other way") • Prohibitions 4 through 10 apply if the item is classed under a specific ECCN or is identified as "EAR99" (meaning items not found on the Commerce Control List - Which generally means that No Export License Is Required … …
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More Rules To Know About • The 10 GENERAL PROHIBITIONS apply to items having a specific ECCN number • General Prohibitions 4 Through 10 apply to items that are EAR99 (or otherwise not found on the Commerce Control List) • The designation "EAR99" was formerly known (prior to
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