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.

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