Frequently Asked Questions
What is an export?
Any item that is sent from the
United States to a foreign destination is an export. "Items"
include commodities, software or technology (e.g. automotive
parts, blue prints, building materials, circuit boards,
clothing, design plans, retail software, and technical
How do I tell if my
product/service is controlled by the export regulations?
All exports are controlled by either the U.S. Department of
State's International Traffic in Arms Regulations (ITAR) or by
the U.S. Department of Commerce's Export Administration
license required for all exports?
No, ITAR covered items usually
do, but most EAR covered items do not. However, some EAR
items do require a license.
If I can't tell if my items
are covered by ITAR, what do I do?
Look at the history. What was it designed or developed for? Was
it designed, developed, or modified for military use? If so, it
is most likely ITAR controlled. You will need to check the
classification in the Munitions List in the ITAR. If they aren't
on the Munitions List, they are covered by EAR.
I can't tell if my
technology or articles are covered by ITAR or EAR, what do I do?
Ask for a Commodity Jurisdiction (CJ) from the
Department of State, Directorate of
Defense Trade Controls (DDTC). M3 Federal International can
help with this.
Do I need to be
registered with the Department of State to request a Commodity
No, you do not.
How do I get a license?
After determining if your item or technology is controlled by
ITAR or EAR, you can request a license online. For an ITAR
license, you need to submit a requesting using DTrade. For EAR
controlled items, you can request a commerce license on SNAP-R.
Your company needs to register with the Department of State (DDTC)
before you can request an online license.
What items need and EAR
Most items covered by EAR are classified as "EAR 99" and don't
require a license. However, you need to check the Commerce
Control List (CCL) to determine the classification. If the item
or technology is on the CCL, you may need a license. It depends
on the Classification (ECCN), where it's going (which country),
and why it's controlled. M3 Federal International can help you
through this determination.
What does "RWA" mean?
RWA stands for "Return Without Action". a license application
may be returned without action if the information is missing or
What is an "EEI"?
EEI stands for "Electronic Export Information". It is the export
declaration that is done online at AESDirect, that notifies
Customs and Border Protection (CBP) of an export. Sometimes this
is called and Automated Export System (AES) or Supplier Export
declaration (SED). This is also used for export statistical
When is an EEI required?
For all exports under a license and non-licensed exports with a
value of $2,500. or more.
If I have an approved
license for the export of 150 pallets of rifle ammunition and my
customer wants another two pallets of the product, can I amend
my license to accommodate this change?
No. There are certain types of
amendments that will not be approved, such as: additional
quantity of commodity, changes in commodity, country of ultimate
destination, end-use or end-user, or extension of duration.
The addition on two pallets of rifle ammunition falls under
"additional quantity of commodity" and therefore would not be
What must we do with our
license if we don't export the entire quantity of the product
If you don't export the entire quantity of the product
authorized, then the license must be returned immediately to the
Department of State.
Questions? Give us a call, or email our experts!