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Export Compliance: Ask The Experts

 

 

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The final rule for Cat XII has finalized, but to definitely be sure that our products will no longer be governed under the ITAR, we submitted a CJ to State.  According to the Order of Review process, our product should be governed by ECCN 0A606.x.  We have a tradeshow we plan to attend in the UK in 2 weeks and a demo in Belgium the following week.  Can we proceed with export under ECCN 0A606.x or should we use DSP licenses?

Obtaining an official ruling is not required.  If you make an accurate determination as to an item's USML or CCL classification, you may proceed based on that.  There is no way for me to know the classification of the item based on the information your provided.  If you feel comfortable with your jurisdiction classification, you should feel comfortable proceeding on that basis.