basic-guide-to-exporting_Latest_eg_main_086196

To learn about the EAR, visit bis.doc.gov, which has videos that explain how to classifyyour products with an Export Control Classification Number (ECCN), if one is needed.If you are unsure whether your product is dual use and you live east of the MississippiRiver, you can call BIS specialists at (202) 482-4811. If you live west of the MississippiRiver, you can call (949) 660-0144. ECCNs are the codes used to classify the productsdetailed in the EAR. This classification concept is similar to the Harmonized System(HS) and Schedule B numbers, but the system used is very different.If you export a small number of products to a small number of countries and noexport license is required, consider designating one person in your company as thecompliance officer. Your export compliance plan need only consist of five elements:1. Classify your products before starting to export them.2. Know the embargoed countries to which you cannot ship or sell.3. Check the denied parties lists at bis.doc.gov for the individuals and institutionsto which you cannot sell.4. Keep records of the transactions (copies of the commercial invoices).5. Include the Destination Control Statement on all commercial invoices, includingones for domestic customers or trading companies in case they sell your productto an international customer.Here’s the Destination Control Statement:“THESE COMMODITIES, TECHNOLOGY, OR SOFTWARE WERE EXPORTED FROM THEUNITED STATES IN ACCORDANCE WITH THE EXPORT ADMINISTRATION REGULATIONS.DIVERSION CONTRARY TO U.S. LAW PROHIBITED.”If you have a catalog of dozens or hundreds of stock-keeping units that you want tosell globally, you should consider creating a written compliance plan. In addition tostudying the online BIS videos and publications, the person responsible for managingyour company’s plan should consider attending specific EAR and export-controlseminars. Visit the BIS website, or ask your local U.S. Commercial Service office forinformation about where to find training. You can also contact BIS for guidance ondeveloping the plan and to review the final document.StrategyEvery dual-use item needs a specific ECCN. When adding a product to your inventoryor reviewing your current product line, ask your suppliers whether they can providethe necessary ECCNs; create a field in your inventory-management system for ECCNs;and add a related field that lists the countries to which export of that product isprohibited by the EAR. If you are obtaining ECCN numbers from your suppliers, workclosely with them to understand how they determine ECCNs.Since the ECCN and any license numbers you receive must appear on exportdocumentation, such as the Commercial Invoice and the Automated Export Systemfiling, this information should be easily accessible in your inventory-managementsystem. As noted above, all dual-use items require a specific ECCN. Items that are not12U.S. Commercial Service • A Basic Guide to Exporting