Every Monday we post the highlights out of last week’s FCC Export/Import Daily Update (“The Daily Bugle”). Send out every business day to approximately 8,000 readers of changes to defense and high-tech trade laws and regulations, The Daily Bugle is a free daily newsletter from Full Circle Compliance, edited by James E. Bartlett III, Alexander P. Bosch, Vincent J.A. Goossen, and John W. Bartlett.
We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOJ/ATF, DoD/DSS, DoD/DTSA, DOE/NRC, FAR/DFARS, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations. Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items. To subscribe, click here.
- Commerce/Census: “Useful Acronyms”; The Daily Bugle; Monday, 5 March 2018, ITEMS #4;
- UK Amends Export Control Order 2008 and 4 OGELs; The Daily Bugle; Monday, 5 March 2018, ITEM #8;
- Singapore Customs Announces Additional TradeNet Downtimes; The Daily Bugle; Monday, 5 March 2018, ITEM #9;
- Dutch Government Publishes Guide Concerning Internal Compliance Programs for Export Controls; The Daily Bugle; Tuesday, 6 March 2018, ITEM #7; and
- UK Updates Consolidated List to Reflect Latest Amendments to Export Control Order 2008; The Daily Bugle; Wednesday, 7d March 2018, ITEM #6.
Commerce/Census: “Useful Acronyms”
(Source: Global Reach Blog, 5 Mar 2018.)
Have you shipped a package overseas that is valued over $2,500 per Schedule B classification number or licensed? Were you told to file Electronic Export Information (EEI) in the Automated Export System (AES) to receive an Internal Transaction Number (ITN)? Are you confused, lost or feel like a contestant on Wheel of Fortune with the abundance of letter combinations presented to you? Rest assured that we are here to help you.
When filing for the first time you are likely to encounter various acronyms that are unfamiliar to you. To assist you with the filing process, here are the most commonly used acronyms:
AES – The Automated Export System is where your reported EEI goes when you file it. This system gathers, processes and stores the export information. AES filers can transmit EEI to the AES via Automated Commercial Environment (ACE) AESDirect, approved self-programming software, approved vendor software, or an approved service center. Government agencies use the data that you report to the system to provide the public with vital statistics about our country’s economy. For a detailed look at these statistics, please visit our webpage.
EEI – Quite simply this means Electronic Export Information. Think of this as an electronic declaration of merchandise leaving the United States and being exported to a foreign country. This will include information about the sender and the receiver of the goods, along with information about the goods being exported.
EIN – The Employer Identification Number is a unique nine-digit number issued by the Internal Revenue Service (IRS). Whether you are a business, or an individual exporting goods, you must obtain this number from the IRS in order to register for an account to gain access to the AES. Individuals wanting to export are advised to apply for an EIN as sole proprietors. See instructions on how to apply.
HTS – The Harmonized Tariff Schedule is a 10-digit number used to classify goods for import. In Step 3 of your filing, you may classify your product with either an HTS code, or a Schedule B number. The choice is yours. Please note that there are HTS numbers that are invalid for export.
IATA – The International Air Transport Association code is how carriers for air exports are identified. You will encounter this field in Step 4 of your filing. Please contact your air carrier for the correct reporting of their IATA.
ITN – The Internal Transaction Number is the confirmation number you receive once your electronic export information is submitted to and accepted by the AES. This number serves as proof of filing in the AES.
SCAC – The Standard Carrier Alpha Code, issued by the National Motor Freight Transit Association, is how carriers for vessel, rail and truck exports are identified. You will encounter this field in Step 4 of your filing. Please contact your carrier for the correct reporting of their SCAC.
Schedule B – This 10-digit number is used to classify the goods that you are exporting. You will encounter this required field in Step 3 of your filing in the ACE AESDirect portal. To classify your goods correctly, please visit our Schedule B Search Engine webpage.
SRN – This refers to the Shipment Reference Number, which is a unique number that you create for each individual shipment. This can be any combination of letters and numbers up to 17 characters. Since this number cannot be reused, you must create a new and unique number for each shipment. You will encounter this required field in Step 1 of your filing in the ACE AESDirect portal.
USPPI – The U.S. Principal Party in Interest refers to the person in the United States that receives the primary benefit, monetary or otherwise, of the export transaction. You will encounter this required filed in Step 2 of your filing in the ACE AESDirect portal.
UK Amends Export Control Order 2008 and 4 OGELs
(Source: UK DIT/ECO, 5 Mar 2018.)
The Export Control Organisation (ECO) of the UK Department of International Trade (DIT) has published the following Notice to Exporters (2018/04).
The export control joint unit (ECJU) has amended the Export Control Order 2008. Changes have been made to article 2 (Interpretation) and Schedule 2 of the order. Four open general export licenses have been amended accordingly.
The new order, The Export Control (Amendment) Order 2018 (S.I. 2018 No.165) comes into force on 5 March 2018. The amending order makes a small number of changes to schedule 2 to the main order, which lists the military goods, software and technology subject to export controls. These changes reflect amendments made to the EU Common Military List following agreement to alter this list in the international export control regime known as the Wassenaar Arrangement.
These changes need to be incorporated into UK legislation to reflect the UK commitment to the international non-proliferation regime. The ECJU will also update the consolidated control list of strategic military and dual-use items that require export authorization.
The changes are:
– the entry for ‘adapted for use in war’ is deleted and a new definition of biological agents has been agreed
– a new heading for ML7 (chemical and biological agents)
– a new substituted entry for ML7.a.
– a new entry inserted as ML8.a.41
– a new substituted entry for ML8.c.3.
– a new entry and technical notes inserted as ML8.h (reactive materials)
In article 2 (Interpretation) the definition of ‘information security items’ has been removed. Changes made by the Export Control (Amendment) Order 2017 (S.I. 2017/85) have made this definition redundant.
Changes to OGELs
The two new entries ML8.a.41 (explosive) and ML8.h (reactive materials) have been excluded from the following OGELs:
Singapore Customs Announces Additional TradeNet Downtimes
(Source: Singapore Customs, 1 Mar 2018.) [Excerpts.]
In addition to the usual housekeeping time for TradeNet on Sundays from 0400 hours to 0800 hours and the extended downtime on 11 March 2018 (as indicated in Notice No. 02/2018), we wish to inform you that Singapore Customs will also be performing system maintenance work which will affect TradeNet for the following dates and times:
|04 March 2018||0400 hours to 1300 hours||9 hours|
|18 March 2018||0400 hours to 1200 hours||8 hours|
|25 March 2018||0400 hours to 1400 hours||10 hours|
|08 April 2018||0400 hours to 1600 hours||12 hours|
|15 April 2018||0400 hours to 1400 hours||10 hours|
During this period, there will not be any processing of amendment, cancellation, refund, and stock related permit applications submitted through TradeNet. Processing of such applications will resume after the indicated timing above. …
Dutch Government Publishes Guide Concerning Internal Compliance Programs for Export Controls
(Source: Dutch Ministry of Foreign Affairs, 21 Feb 2018.)
The Dutch Ministry of Foreign Affairs has published on its website a guide (in Dutch) concerning Internal Compliance Programs (ICP) for Export Controls
An ICP is mandatory for organizations that apply for and use a Global Export License. An ICP must consist of at least the following elements:
(1) Management Commitment
(2) Structure & Responsibility (“Compliance Organization”)
(3) Export Screening Procedure
(4) Pre-Shipment Controls
(6) Audits, Reporting & Enhancement Measures
(7) Archiving (“Record keeping”)
UK Updates Consolidated List to Reflect Latest Amendments to Export Control Order 2008
(Source: UK DIT/ECJU, 6 Mar 2018.)
The Export Control Joint Unit (ECJU) of the UK Department of International Trade (DIT) has updated the consolidated control list of strategic military and dual-use items that require export authorization. The changes reflect amendments to the Export Control Order 2008, which came into force on 5 March 2018.
The Export Control (Amendment) Order 2018 (S.I. 2018 No.165) made a small number of changes to schedule 2 to the main order, which lists the military goods, software and technology subject to export controls. For more information, see: “Notice to exporters 2018/04: Export Control Order 2008 amended, also 4 OGELs.”