M3 Federal International, LLC
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Frequently Asked Questions

What is an export?
Any item that is sent from the United States to a foreign destination is an export. "Items" include commodities, software or technology (e.g. automotive parts, blue prints, building materials, circuit boards, clothing, design plans, retail software, and technical information)

How do I tell if my product/service is controlled by the export regulations?
All exports are controlled by either the U.S. Department of State's International Traffic in Arms Regulations (ITAR) or by the U.S. Department of Commerce's  Export Administration Regulations (EAR).

Are license required for all exports?
No, ITAR covered items usually do, but most EAR covered items do not. However, some EAR items do require a license.

Frequently Asked Export Questions and Answers

If I can't tell if my items are covered by ITAR, what do I do?
Look at the history. What was it designed or developed for? Was it designed, developed, or modified for military use? If so, it is most likely ITAR controlled. You will need to check the classification in the Munitions List in the ITAR. If they aren't on the Munitions List, they are covered by EAR.

I can't tell if my technology or articles are covered by ITAR or EAR, what do I do?
Ask for a Commodity Jurisdiction (CJ) from the Department of State, Directorate of Defense Trade Controls (DDTC). M3 Federal International can help with this.

Do I need to be registered with the Department of State to request a Commodity Jurisdiction?
No, you do not.

How do I get a license?
After determining if your item or technology is controlled by ITAR or EAR, you can request a license online. For an ITAR license, you need to submit a requesting using DTrade. For EAR controlled items, you can request a commerce license on SNAP-R. Your company needs to register with the Department of State (DDTC) before you can request an online license.

What items need and EAR license?
Most items covered by EAR are classified as "EAR 99" and don't require a license. However, you need to check the Commerce Control List (CCL) to determine the classification. If the item or technology is on the CCL, you may need a license. It depends on the Classification (ECCN), where it's going (which country), and why it's controlled. M3 Federal International can help you through this determination.

What does "RWA" mean?
RWA stands for "Return Without Action". a license application may be returned without action if the information is missing or incorrect.

What is an "EEI"?
EEI stands for "Electronic Export Information". It is the export declaration that is done online at AESDirect, that notifies Customs and Border Protection (CBP) of an export. Sometimes this is called and Automated Export System (AES) or Supplier Export declaration (SED). This is also used for export statistical purposes.

When is an EEI required?
For all exports under a license and non-licensed exports with a value of $2,500. or more.

If I have an approved license for the export of 150 pallets of rifle ammunition and my customer wants another two pallets of the product, can I amend my license to accommodate this change?
No. There are certain types of amendments that will not be approved, such as: additional quantity of commodity, changes in commodity, country of ultimate destination, end-use or end-user, or extension of duration.  The addition on two pallets of rifle ammunition falls under "additional quantity of commodity" and therefore would not be approved.

What must we do with our license if we don't export the entire quantity of the product authorized?
If you don't export the entire quantity of the product authorized, then the license must be returned immediately to the Department of State.


 

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