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Export Trade Compliance - Exactly What Every Contract Maker Needs To Know About Export Compliance

By Author: Wilton Nasuti
Total Articles: 2

Contract manufacturers (CMs) have actually become the de facto manufacturing division for lots of U.S. business. The reasons for this continuous trend consist of outsourcing non-core proficiencies (i.e. manufacturing), lowering supply chain expenses, decreasing capital expenditures, and structure versatility into production operations.

The CM's client who exports is needed to comply with the U.S. Department of Commerce Export Administration Laws (EAR) and the UNITED STATE Division of State International Traffic in Arms Laws (ITAR). The EAR has jurisdiction over "dual use" items, that is, those products with both military and commercial applications, while ITAR has jurisdiction over defense short articles. What about the CM's export compliance requirements? My information is put together from trade services.

CMs need to first establish whether the products or assemblies they produce are under the jurisdiction of ITAR or EAR. For this reason it is important that the CM have a mutual understanding of their customer's company. Getting drawings stamped "ITAR Controlled" are a sure thing that the products fall under ITAR jurisdiction. Are the assemblies used in satellite, aerospace or defense applications? Are the items used in telecommunications or commercial applications? If so, what are completion short articles produced and exactly what are their end-uses? CMs will likely currently understand the answers to these concerns, which will assist to figure out the product territory.

Items under ITAR territory are defined on the UNITED STATE Munitions List (USML), which can be discovered in CFR 22, Part 121. In addition to ammo, missiles and explosives, this list consists of military vessels, cars, plane, training devices, protective workers equipment, military electronic devices, optical and assistance control equipment.

It is imperative that the CM understands that the USML includes elements, parts, devices, attachments, and connected equipment particularly developed or modified for use with the equipment in each of the USML classifications. The subassemblies that a CM produces are regulated on the USML.

Items under EAR territory can be discovered on the Commerce Control List (CCL) in CFR 15, Part 774. The CCL consists of products (commodities, software, and innovation) subject to the authority of the UNITED STATE Department of Commerce, Bureau of Market and Security (BIS) and include "dual use" products along with purely commercial products. The CCL does not consist of those products solely managed for export by an additional division or company of the UNITED STATE Government. In instances where various other firms administer controls over associated items, entries in the CCL will consist of a reference to these controls.

If you are unsure of the export jurisdiction of an item or service, you need to request a commodity jurisdiction (CJ) determination from the UNITED STATE Department of State, Directorate of Defense Trade Controls (DDTC).

WHAT DOES A CM DEMAND TO UNDERSTAND ABOUT EXPORT COMPLIANCE?

Under ITAR Jurisdiction

-Registration with the Division of State (DDTC). This is required even if the CM does not export the regulated products
-Alert of the DDTC of violations of criminal statutes, modifications in senior management, modifications in foreign ownership, and acquisitions and mergers
-Maintenance of records concerning the manufacture, acquisition and personality of defense short articles and technical information
-Application for licenses (or use of proper exemption) for exports of items on the USML
-Application for licenses (or use of appropriate exemption) for innovation transfers of products on the USML to foreign persons or entities

Under EAR Territory

-Application for licenses (or use of appropriate exception) for exports of items on the CCL and Commerce Nation Plan as needed
-Application for licenses (or use of suitable exception) for innovation transfers to foreign persons or entities of items on the CCL and Commerce Country Graph as required
-Checking on end-user versus government lists of forbidden parties/entities
-Guaranteeing that products are not planned for restricted end-uses (i.e. WMD).

Failure to comply with these federal policies can result in considerable criminal charges (possible prison sentences and fines) and civil action (e.g., fines and rejection of export advantages).

Compliance Guarantee LLC offers detailed import and export compliance trade, assessment, and training management systems. Solutions are offered for U.S. business and their foreign subsidiaries as well as non-U.S. business bound by U.S. export laws.


The CM's consumer who exports is needed to comply with the U.S. Department of Commerce Export Administration Laws (EAR) and the U.S. Department of State International Traffic in Arms Regulations (ITAR). The EAR has territory over "dual use" products, that is, those items with both industrial and military applications, while ITAR has territory over defense articles. What about the CM's export compliance requirements?

The CCL consists of products (products, software, and innovation) target to the authority of the UNITED STATE Department of Commerce, Bureau of Market and Security (BIS) and consist of "dual use" products as well as purely commercial items. The CCL does not consist of those products specifically regulated for export by an additional department or firm of the U.S. Government. To get extra information please check out business barter exchange.

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