Export License Requirements of Direct Commercial Sales v Foreign Military Sales

EAR, Export Controls, Export License, ITAR, License Exemption, Licensing

Political instability around the world is creating a boom for U.S. arms exports, and it’s putting the spotlight on the important difference between Direct Commercial Sales (DCS) and Foreign Military Sales (FMS). The U.S. State Department reports that authorized sales...

Exporting 600 Series Items Under License Exceptions

EAR, ECCN, ITAR, License Exceptions

On the Commerce Control List (CCL), items controlled in the 600 series (those with a “6” as the third character of the ECCN) are military items, most of which were previously controlled on the United States Munitions List (USML) and subject to the ITAR. Such sensitive...

How Export Regulations Impact Domestic Activities

EAR, Export Compliance, Export Controls, ITAR, US

It comes as a surprise to many that certain activities governed by U.S. export control regulations don’t necessarily involve sending things out of the United States. And among those who already know this, many believe there are requirements to follow which, in fact,...

Understanding the Difference Between the Various Country Lists in the EAR

Countries, EAR

There are multiple ways the EAR organizes and identifies countries for exporters. Keeping them straight can be a challenge. Here’s an overview of each listing of nations and the purpose it serves. Commerce Country Chart Supplement No. 1 to Part 738 of the EAR Primary...

Navigating the Special U.S.-U.K. Trade Relationship

EAR, Export Compliance, Export Controls, UK

The United Kingdom (England, Scotland, Wales and Northern Ireland) has historically been one of the United States’ best trading partners, which provides unique opportunities for exporters. The 2007 Defense Trade Cooperation Treaty between the United States and United...

6 Common Errors in Applying the EAR99 Classification

EAR, EAR99, ECCN

Most items that get exported from the United States are handled under the export control classification of EAR99. For many exporters – particularly those shipping relatively low-tech consumer or industrial products – it’s the only export classification they know or...