ITAR training points

Three areas of export control laws. The International Traffic in Arms Regulations or ITAR, which is administered by the State Department. These apply to military products. The Export Administration Regulations or EAR, administered by the Commerce Department. These apply to commercial products that have some use in the military or intelligence area and the U.S. Sanctions Laws, administered by the Treasury Department’s Office of Foreign Assets Control.

The first cornerstone concept under ITAR – ITAR contains a list of products called the U. S. Munitions List (USML) If your product is on this list, it is subject to these controls. This is a key concept. If your product is on the list, everything else flows from this. If you look down the list, you will see that the majority of headings- a lot of the items in the beginning of the list are truly defense items: firearms, guns, explosives, naval vessels. But, if you look farther down the list, you will see that the categories start to overlap with commercial items – training, electronics, chemicals, satellites. So it is sometimes difficult to determine if your product is on the list or not

Another cornerstone concept is that these controls apply not just to physical products, but also to software and technical data, as well. So, if an item is on the list such as a navigational device – the software used to run that device is also on the list, and the technical data related to the device is on the list. Technical data refers to drawings, algorithms, manuals, any information on the design, manufacture, or use of the item. So, if the product is on the list, then the electronic files are on the list, the specification sheets, the technical manuals – are all on the Munitions List and subject to ITAR.

https://www.sbir.gov/tutorials/itar/tutorial-1#

Customs Broker Audit insight

From 31 broker penalty cases

Clustered results

incidents of accounting and financial deficiencies (more than one type) 39+

not properly maintaining employee list     17+

powers of attorney 14+

responsible supervision and control 8+

failed recordkeeping general 6+

lots of other issues not listed at this time = Above indicates where brokers should focus attention and of course follow Customs Regulations especially Part 111

 

need manual, focus on training and internal reviews – exercise responsible supervision

import export compliance hts classification

CLASSIFICATION Best way is to have the HTS Index. Search with term and see if it is listed. Refer to the referenced HTS number(s). Apply the GRIs. GRI 1 will be applicable most of instances…but follow the other GRIs as applicable.

Retired FNIS Maready instructed on classification in Southeast U.s. Retired FNIS Key also taught. We are not the best but in that class. We can make you better and cut through the clutter.

 

Clement Key CHB License, Gerald Maready CHB License – both retired FNIS

704 664 2932 call we’ll help you to be better

http://exportimportcompliance.com/index.php