Clarification of ECCN numbers – whose responsibility to obtain? UK manufacturer or US distributor?

Question

(This question was asked at one of our recent webinars on Export Controls. You can listen to this webinar on our recent webinars page at http://opentoexport.com/info/webinars/)

Answer

The US supplier should advise you of the export control classification number, but if you are re-exporting the item you are then the person responsible for the correct classification and it is possible to self classify the product – but make sure you record the thought process and your conclusions.

It is a sad fact that there are some US manufacturers who are not aware of their own export regulations due to the size of the domestic market in the USA.

Answer

David, many thanks for your response. However, the question has been slightly misconstrued. The US branch of one of our UK distributors has asked us to supply the ECCN for a product we manufacture here in the UK. Not sure why they need it. If they are re-exporting it, I thought it would be the distributor’s responsibility to find the ECCN. Just trying to clarify. As you say, it might just be a case of the US distributor not being aware of their own export regs.

Answer

Thanks for the clarification Carole.

If you are manufacturing a controlled item and providing it to a UK distributor, while there is no licence requires you should be advising them that the goods are controlled if they are to subsequently export them. As a result you would provide the classification to the distributor as you are the person best places to classify the item having designed/built it.

The US party would then require the information as once the item has entered the USA it is then subject to the US regulations and the ECCN would be required for re-export.

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