COMMODITY EXPORT JURISDICTION/COMMODITY CLASSIFICATION
Your company has developed a new product or software, and before export takes place, your company desires to understand the export jurisdiction and export classification ramifications, so that you can market your product or software for sale in accordance with the export regulations, International Traffic in Arms Regulations (“ITAR”) or Export Administration Regulations (“EAR”). FD Associates will work with your company export compliance personnel and engineers to review the product or software capabilities and, using the ITAR and EAR’s Order of Review, develop a position paper on the specific export jurisdiction and export classification of your product or software and provide guidance pertinent to making future exports.
Based on the self-determination, a formal determination of commodity export jurisdiction may need to be filed with the Department of State to valid self-determination results. FD Associates has filed over 100 Commodity Jurisdiction (CJ) requests, including appeals, and we can assist your company with the development of the CJ filing. The CJ process is also useful for companies that believe their ITAR product or software should be regulated by the EAR due to new non-military use of the product or software. FD Associates can aid your company with preparing CJs or appealing past CJ outcomes.
COMMODITY CLASSIFICATION REQUESTS
Items not regulated by the ITAR are regulated by the EAR. FD Associates supports many clients with the determination of the Export Control Classification Number (ECCN) under the EAR for their non ITAR commodities, software, or technology ranging from purely commercial or civil products or software such as software with encryption and encryption software, tools and equipment for manufacturing, scientific equipment, medical, aerospace systems and parts, gas turbine engine technology, and firearms/ammunition systems to those that are for use in or with military platforms regulated by the ITAR. FD Associates assists clients with the development and submission of formal Commodity Classification Application Tracking (CCATS) request to the Department of Commerce, Bureau of Industry and Security for formal determinations when requested or mandated by the EAR.