Are You Prepared to Make That “Commercial Parts” Export?

Scenario: Your company is asked to export small castings to a customer in Singapore. You say to yourself, no worries since these castings are not ITAR parts. Here is what most companies do not realize, if the parts are NOT ITAR but are actually Dual-Use and are subject to the EAR, then here is a just a small sample of what they must understand:

§758.3   Responsibilities of parties to the transaction.

All parties that participate in transactions subject to the EAR must comply with the EAR. 

Parties are free to structure transactions as they wish, and to delegate functions and tasks as they deem necessary, as long as the transaction complies with the EAR. 

However, acting through a forwarding or other agent, or delegating or redelegating authority, does not in and of itself relieve anyone of responsibility for compliance with the EAR.

Do you understand and comply with Part 758 Export Clearance Requirements which include:

§758.1   The Electronic Export Information (EEI) filing to the Automated Export System (AES).

§758.2   Automated Export System (AES).

§758.3   Responsibilities of parties to the transaction.

§758.4   Use of export license.

§758.5   Conformity of documents and unloading of items.

§758.6   Destination control statement and other information furnished to consignees.

§758.7   Authority of the Office of Export Enforcement, the Bureau of Industry and Security, Customs offices and Postmasters in clearing shipments.

§758.8   Return or unloading of cargo at direction of BIS, the Office of Export Enforcement or Customs Service.

§758.9   Other applicable laws and regulations.


Contact AEI at