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Can you Really Rely on the Destination Control Statement?

Over the past month, our firm has been engaged by a reseller of electronic components to assist their company in making license determinations for a wide range of integrated circuits and microprocessors falling under various subcategories of ECCN 3A001. Our word to the wise is “use caution” when evaluating and exporting items under this ECCN. The ECCN is subject to National Security (NS) column II export controls. However, if the IC’s are radiation hardened (i.e. ECCN 3A001.a.1.a) and “usable in missiles” than they are also subject to missile technology controls. Missile technology controls also apply if the components are designed for military use and operable under extreme temperature ranges. And […]

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