For equipment which is made in a number of countries including the US, are we subject to US controls on all items, or only on those manufactured in USA?

Question

we are a supplier of siemens industrial equipment which is made in a number of countries around the world including USA and they puplish AL & ECCN codes. I understand that we are subject to UK/EU export controls, but are we subject to US controls on all items, or only on those manufactured in usa

(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

You will definitely be subject to the US export regulations on the items that were manufactured in the USA, but there is also the issue of US regulation "infection" on items that were manufactured outside the USA if they were made using US origin technology. There is also the possibility that goods purchased from outside the USA were originally manufactured in the US if you are buying from distributors.

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