Exporting Overseas

Dear M & M:

I am interested in exporting a product overseas. This product does not require an export license. I am not sure who the end user will be as they are selling to a third party. Is there something I need to do to make sure I am in compliance with regulations?

– Randy.

Dear Randy:

If your item falls under the jurisdiction of the U.S. Department of Commerce and is not listed on the Commercial Control Lists, and it does not require and export license it is designated as EAR99.

Generally the majority of commercial products are designated EAR99 and generally will not require a special license to be exported or imported into this country and later re-exported.

However, if you plan to export an EAR99 item to an embargoed or sanctioned country, to a party of concern, or in support of a prohibited end-use, you may be required to obtain a license.

The Bureau of Industry and Security (BIS) have what they call advisory opinions relating to what they call red flags when exporting to another country. The following link has general topics one should check out if you suspect something is wrong http://www.bis.doc.gov/index.php/policy-guidance/advisory-opinions.

Not knowing the end user especially if your product can be refitted to serve another purpose or knowingly suspect a third party reselling your items to a country that the U.S.  has sanctioned can get you into trouble.

The Export Counselling Division of the Office of Exporter Services can be reached at any of the numbers below: (202) 482-4811 – Outreach and Educational Services Division (located in Washington, DC), (949) 660–0144 – Western Regional Office (located in Newport Beach, CA), (408) 998-8806 – Northern California branch (located in San Jose, CA).

You can e-mail your questions to the Export Counselling Division of the Office of Exporter Services at: ECDOEXS@bis.doc.gov . Locally, you can contact Cochise College Small Business Development Center (SBDC) for specialized assistance in international trade.

 -M&M

To ask your questions: Call the Small Business Development Center(SBDC) at Cochise College (520)-515-5478 or email schmittm@cochise.edu or contact the Sierra Vista Economic Development Foundation(EDF) at 520-458-6948 or email  hollism@svedf.org

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