COMMODITY JURISDICTION REQUESTS
There are several scenarios where company’s find that they should file a Commodity Jurisdiction (CJ) request with the Department of State to obtain a legally binding ruling on the export jurisdiction of their commodity, technology, software, services.
- IR&D with funding from the U.S. DOD
- IR&D of item intended for use in commercial and military markets with first sales to military
- New product development for commercial, civil, industrial or scientific marketplace that includes an ITAR part or component
- Existing product, where sales were primarily military initially but commercial sales/civil end use has become predominant
- Questions from the Department of Commerce or U.S. Customs and Border Protection regarding the export jurisdiction of the product being licensed for export or being exported
- Voluntary Disclosure filing after determination that self-classification of product, software, service, technical data or technology may be incorrect
The Department of State does not have the bandwidth to process millions of CJs each year, thus the ITAR spells out the Order of Review and allows companies to self-classify. This self-classification is the underpinnings of every export decision made thereafter regarding the export of the product, software, service, technical data or technology.
FD Associates will work with your company export compliance personnel and engineers to review the product, software, technical data or service and using the ITAR and EAR’s Order of Review, we can develop a position paper on the specific export jurisdiction and export classification of your product or software and provide guidance pertinent to making future exports.
Should a formal determination be required, for the reasons stated, a CJ can be prepared and filed with the Department of State to valid self-determination results.
FD Associates stands at the ready to support your requirement and has filed over 150 Commodity Jurisdiction (CJ) requests, including appeals for our client base.
COMMODITY CLASSIFICATION REQUESTS
Items not regulated by the ITAR are regulated by the EAR. FD Associates supports many clients with the determination of the Export Control Classification Number (ECCN) under the EAR for their non ITAR commodities, software, or technology ranging from purely commercial or civil products or software such as software with encryption and encryption software, tools and equipment for manufacturing, scientific equipment, medical, aerospace systems and parts, gas turbine engine technology, and firearms/ammunition systems to those that are for use in or with military platforms regulated by the ITAR. FD Associates assists clients with the development and submission of formal Commodity Classification Application Tracking (CCATS) request to the Department of Commerce, Bureau of Industry and Security for formal determinations when requested or mandated by the EAR.
FD Associates is well versed in the variety of articles, services and technology and how to help companies classify their items. Call us for a free consultation at 703-847-5801, or email us.