This Guidance does not create any privileges, benefits, or rights, substantive or procedural, enforceable by any individual, organization, party, or witness in any administrative, civil, or criminal matter.



Q.25: Are there paragraph (b) ‘releases’ that address scenarios where the “part,” “component,” “accessory,” “attachment,” or “software” was or is being “developed” for use in or with commodities or software described in ECCNs and also for use in or with EAR99 items or items described in AT-only ECCNs?

A.25: Paragraph (b)(4) addresses these types of scenarios. Provided you have documentation contemporaneous with its "development" establishing "knowledge" that the "part," "component," "accessory," "attachment," or "software" was "developed" for use also in or with AT-only or EAR99 items, paragraph (b)(4) would serve as a ‘release’ from "specially designed."

© BIS 2019