CONQUERING THE CCL POST-REFORM

The Latest, Best Practices for Updating Your Self-Classification Approach – and How Exporters are Classifying Under the “Specially Designed” Framework

June 5, 2018 9:15am

Barbara Dudas
Manager, International Trade Compliance – Mission Systems
Northrop Grumman Corporation (Chicago, IL)

Arthur Ward
Regulatory Compliance Officer
Cartridge Actuated Devices, Inc (New York, NY)

Best practices for navigating CCL categories, product groups and series
  • Military items controlled under the EAR and the 600 Series
  • Determining the ECCN for your product
    • Questions to ask when classifying new technologies and conducting market and IT functionality analyses
    • When to contact the manufacturer, producer or developer
    • Determining the appropriate CCL Categoryand Group
    • How to apply the “specially designed” criteria in the CCL
    • How to match specific characteristics of your item to an ECCN
  • What to do once you obtain your ECCN, and how to determine if an export license is required
  • What do you do if no ECCN fits your product?
  • When and how to submit a commodity classification request (CCATS) to BIS
  • Tips and tricks for self-determining items as “specially designed” and understanding exemptions
  • How to successfully “catch” and “release” – navigating paragraph (a) and (b)
  • The most common pitfalls in the new “catch” and “release” process
  • Documentation and appropriate record keeping to support your determination