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U.S. Controls On The Export And Re-export Of
U.S. Origin Goods & Technology - Export Management Procedures
  1. Export Procedures & Best Practices:   Guidance For Exporters & Forwarders

As a general rule, companies that engage in the export of electronics and related commodities and technology will have the following:

    1. A process to categorize and classify commodities before they are exported

    2. A process to categorize and classify technical data before it is exported or disclosed to foreign nationals

The process to categorize and classify products and technical data should be as follows:

    1. Train and educate engineers or technical staff to recognize, categorize, and classify commodities or technical data under the ITAR or EAR

    2. Develop and maintain a record of classifications that can be shared and updated, as needed.

    3. When in doubt as to the correct category or classification, seek guidance from the appropriate agency (State or BIS), using the requisite forms (CJ or BIS form)

Additionally, you will need to maintain appropriate export documents and records, including records of technical data transfers (what was transferred and to whom) for a period of five years from the date of export.

Finally, you will want to develop and implement written procedures for foreign entities regarding compliance with U.S. law for products that are subject to U.S. export control jurisdiction (either exported from the U.S. or a foreign-made product designed or manufactured from U.S.-origin technology).  

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