Export Controls: How to deal with and item not on the control list but components are ?

Question

There are times when an item/kit does not fall into a control list category. but has components in them that may make them controlled. How do we deal with these things?

(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

When classifying an item, you look for the item itself in the Control Lists. You do not normally need to check each component that makes up the item you are exporting. Exceptions to this are 1. If the item is easily removable (i.e plugged into a socket or a separate item in a kit of parts) then it needs to be considered in its own right and 2. If the item is the ‘principal element’ of the item – See General Note 2 at the start of Annex I (The EU Dual Use List).

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