BIS Revises Required Support Documentation for Export Licenses under Part 748 of the EAR

In a final rule published in the Federal Register on Friday, March 13th [80 FR 13212] the Bureau of Industry and Security revised the requirements for support documentation to accompany license applications under Part 748 of the EAR. Most notably, the new rule (effective as of March 13, 2015) removes the requirement for obtaining International Import Certificates or Delivery Verification on license applications. For our clients who are exporting to China, sorry but this new rule did not eliminate the need to obtain the well known “China MOFCOM” on exports in excess of $US 50,000.

Most notably, this new rule eliminates the need to obtain a BIS 711 or Statement by Ultimate Consignee and Purchaser for all exports, re-exports and transfers (in-country) except “series 600” Major Defense Equipment. At TSI Global Consulting, we view this change in a positive light as this new rule represents a significant streamlining and reduction of paperwork required for licensed transactions. However, we also view the BIS 711 as an assurance document and over the coming weeks we will be evaluating and in many cases recommending to our clients that they obtain other forms of written assurance in order to document and ensure against potential diversion and unauthorized use of export controlled products, technology, and software. For further information on this new rule please contact the office.

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