Is thickness of the inorganic overlay coatings considered controlled technology under 2E003.f?
(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/)
Thank you for your question.
Unfortunately there currently isn’t a Control List Classification service that can formally answer this question, and if after making your own assessment you are unsure of the Classification of your Technology, then I would advise that you apply for a licence accordingly. Please include a review of your own attempt at rating your technology so that a Technical Assessment Officer can review your assessment to aid theirs. Remember to also include all technical details required to assess your Technology against the controls.
However, it is feasible that such thickness information may be considered controlled "technology", but it is ultimately the exporters responsibility to review the controls, including the General Technology Note (GTN), definition for "technology" and the decontrols therefor, when making an assessment.
And please remember to consider the control entries relating to goods if they are being manufactured using this process (such as Category 9).