Q.1: I exported an item under the International Traffic in Arms Regulations (ITAR), but it transitioned to the “600 series” while located overseas after I exported it. What do I need to do to bring it back to the U.S. for servicing under the.....

Q.1: I exported an item under the International Traffic in Arms Regulations (ITAR), but it transitioned to the “600 series” while located overseas after I exported it. What do I need to do to bring it back to the U.S. for servicing under the Export Administration Regulations (EAR)?

A.1: Unlike under the ITAR, there are no temporary import licensing requirements under the EAR. No license is required for the item to come back to the United States. To return the serviced item to your customer overseas, consult License Exceptions under part 740 of the EAR to see if any are available for your transaction. Section 740.2 sets forth restrictions on license exceptions in general, with section 740.2 (a)(13) providing a list of license exceptions available for "600 series" items. You may, for example, meet the terms and conditions of License Exception Servicing and Replacement of Parts and Equipment (RPL) in section 740.10 and be able to use that authorization to return the serviced item. If no license exceptions are available, apply to BIS for a license.

Q.2: Many of my formerly ITAR-controlled items became “600 series” items on October 15, 2013 and other items became “600 series” items on January 6, 2014. I am still shipping them under my Directorate of Defense Trade Controls (DDTC) license in......

Q.2: Many of my formerly ITAR-controlled items became “600 series” items on October 15, 2013 and other items became “600 series” items on January 6, 2014. I am still shipping them under my Directorate of Defense Trade Controls (DDTC) license in accordance with the transition procedures. Do I need to report the “600 series” Export Control Classification Numbers (ECCNs) in Automated Export System (AES) along with my DDTC license?

A.2: You are not required to report the ECCNs of "600 series" items shipped under grandfathered DDTC licenses during the transition period. However, you may do so without making an AES error.

 

   
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