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
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
