How is a non-dual use assembly that contains a dual use part categorised?

Question

How would you categorise a non dual use assembly that contains a dual use item? Example would be a basic process skid that contains one valve with high nickel content

(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 considering an item against the Strategic Export Control Lists you consider the item presented for export and not normally the parts it is made up from. If you were exporting a mobile phone, you would look in Category 5 of the Dual Use list and find no entry that covers it. You would not need to consider the accelerometer or GPS system that most phones now contain as they are integral to the phone. The exceptions are if the controlled item is ‘easily removable’ or if it is the ‘principal element’ of the item in which case you would need to consider it as a separate item against the Control Lists. In the case of a mobile phone or any item that has encryption, you would also need to check against Category 5 Part 2.

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