Specially Designed: Get It Right and Your Exports May Benefit

Two Words that May Have a Surprising Impact on Your Classifications


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It has been over two years since “specially designed” became the two most important words in export compliance classifications. Nonetheless, it is not easy to get a handle on how the detailed and complex EAR and ITAR definitions affect your export classifications.

At first glance, you might not notice their dramatic impact on the ITAR and EAR classifications for a wide range of electronics, satellite, aircraft, engine and missile-related items. If you take a closer look, and perform a systematic analysis of “specially designed,” you may find some dramatic, and, in fact, sometimes hard to believe changes and relaxations in your ITAR and EAR export classifications.

Unfortunately, some of the benefits that “specially designed” gives to your exports may be counter intuitive, if not downright illogical.  Did you know that you could design a part uniquely for a bomb, have it used only in a bomb, but it still may not be controlled as specially designed for a bomb? In fact, that part could be classified as EAR99 and eligible for export as No License Required to nearly all countries.

The biggest impact of Export Control Reform is the dramatic shift of a wide range of military items off of the US Munitions List (USML) and onto the Commerce Control List (CCL). Nothing plays a bigger role in this major relaxation of US export controls than the term “specially designed.” There are two important things about “specially designed” that you must understand. First, it plays an unprecedented significant role in relaxing US export controls on many products and technologies. Second, it is extremely complex and difficult to understand.

Fortunately, it is not impossible to understand and apply, especially if someone sorts through the voluminous regulatory and rule-making language to show you what you need to know and understand. Once you get on the right track, before you know it, you will be skilled and confident in using “specially designed” for your export classifications.

Our webinar will include:

  • The “catch and release” approach in “specially designed”
  • The across the board decontrol of certain things such as fasteners, springs, grommets, etc.
  • The decontrol of single use military items, because they are not “specially designed”
  • The decontrol of things with similar, but not identical, form and fit as lesser controlled items
  • The decontrol of items intended for use in highly controlled items and lesser controlled items
  • The decontrol of general purpose items
  • The (b)(2) release “sliding board” that moves many former highly controlled ITAR parts to EAR99 status
  • The continued use of the undefined “specifically designed” in many USML categories
  • Tips and ideas for how to go about reclassifying your products based on the new definition
  • A question and answer period to clarify your burning questions

And if you think 60 minutes is too long to talk about just one definition, you obviously have not yet read and studied the 20 or so pages of fine print in the Federal Register notices related to “specially designed.”

All attendees will receive a copy of the webinar training materials, including notes and access to the recorded version of the webinar for a period of one year—two tools that will come in very handy as you work to use, and apply specially designed in your job. Webinar participants will also be invited to submit questions during the webinar; the final 30 minutes of the webinar will be allotted to answering attendees’ questions.

John Black will use his 31+ years of experience and concrete examples to show you how to understand, apply and take advantage of this complex and exporter-friendly new term.  For many companies, the rewards of mastering “specially designed” are discovering relaxed export controls on many items.  This webinar will provide PowerPoint slides and include video and commentary from John, who has worked with a wide range of companies to study and apply “specially designed” and has already conducted well over 20 training sessions on this critical term.


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Webinar Details:

Recorded Apr 27, 2016
Length 1 hour 30 minutes
Comprised of 1 hour of commentary and 30 minute Q & A session
Cost $150 per person
Multi-Viewer Discounts Available
ECoP® EAR or ITAR renewal credits: 1
NEI / NCBFAA
Event #: 11191
CES: 1.5
Additional Notes

1 Viewer $150
2 Viewers $225
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