Comments on: If You Have an Export Law Question, Don’t Ask the Wall Street Journal http://www.exportlawblog.com/archives/199 Latest News on DDTC, BIS, OFAC, and other export law matters Fri, 10 Feb 2012 10:06:23 +0000 hourly 1 http://wordpress.org/?v=3.0 By: Matthew J. Lancaster http://www.exportlawblog.com/archives/199/comment-page-1#comment-3156 Matthew J. Lancaster Fri, 03 Aug 2007 01:53:46 +0000 http://www.exportlawblog.com/archives/199#comment-3156 Sure thing, Clif. Here is the site I have bookmarked thanks to Scott Gearity's collection efforts: http://www.apple.com/legal/export.html Sure thing, Clif. Here is the site I have bookmarked thanks to Scott Gearity’s collection efforts:

http://www.apple.com/legal/export.html

]]> By: Clif Burns http://www.exportlawblog.com/archives/199/comment-page-1#comment-3153 Clif Burns Thu, 02 Aug 2007 21:43:48 +0000 http://www.exportlawblog.com/archives/199#comment-3153 That's interesting, Matthew. Do you have a link to that matrix? It adds an interesting context to the whole initiative to deny luxury goods to NK if the iPod, which was exhibit no. 1 under that initiative, was already controlled for export to NK under 4A994. That’s interesting, Matthew. Do you have a link to that matrix? It adds an interesting context to the whole initiative to deny luxury goods to NK if the iPod, which was exhibit no. 1 under that initiative, was already controlled for export to NK under 4A994.

]]> By: Matthew J. Lancaster http://www.exportlawblog.com/archives/199/comment-page-1#comment-3149 Matthew J. Lancaster Thu, 02 Aug 2007 21:07:33 +0000 http://www.exportlawblog.com/archives/199#comment-3149 According to Apple's online Export Compliance matrix, the standard 30GB iPod is ECCN 4A994. Its nylon carrying case is EAR99... According to Apple’s online Export Compliance matrix, the standard 30GB iPod is ECCN 4A994. Its nylon carrying case is EAR99…

]]> By: Clif Burns http://www.exportlawblog.com/archives/199/comment-page-1#comment-3036 Clif Burns Tue, 24 Jul 2007 15:50:11 +0000 http://www.exportlawblog.com/archives/199#comment-3036 That's correct, as I explained <a href="" rel="nofollow">here</a>. All items other than food and medicine require licenses, although there is a general policy of approval for EAR99, and a general policy of denial for luxury items. I didn't make this clear in the post because the UNDP exports were made prior to this new rule coming into effect in January 2007. That’s correct, as I explained here. All items other than food and medicine require licenses, although there is a general policy of approval for EAR99, and a general policy of denial for luxury items. I didn’t make this clear in the post because the UNDP exports were made prior to this new rule coming into effect in January 2007.

]]> By: Export Guy http://www.exportlawblog.com/archives/199/comment-page-1#comment-3035 Export Guy Tue, 24 Jul 2007 14:58:44 +0000 http://www.exportlawblog.com/archives/199#comment-3035 But what is the requirement today? The regulation you link to, FR of Jan 26, 2007 states "...the Bureau of Industry and Security (BIS) will require a license for the export and reexport to North Korea of all items subject to the Export Administration Regulations (EAR), except food and medicines that are not on the Commerce Control List (CCL). The EAR states in several places that items subject to the EAR which are not listed on the CCL are designated as "EAR99." Doesn't this mean that today, you need a license for everything except food and medicine that doesn't show up in a CCL category? But what is the requirement today? The regulation you link to, FR of Jan 26, 2007 states “…the Bureau of Industry and Security (BIS) will require a license for the export and reexport to North Korea of all items subject to the Export Administration Regulations (EAR), except food and medicines that are not on the Commerce Control List (CCL). The EAR states in several places that items subject to the EAR which are not listed on the CCL are designated as “EAR99.”
Doesn’t this mean that today, you need a license for everything except food and medicine that doesn’t show up in a CCL category?

]]> By: Clif Burns http://www.exportlawblog.com/archives/199/comment-page-1#comment-3030 Clif Burns Tue, 24 Jul 2007 02:01:54 +0000 http://www.exportlawblog.com/archives/199#comment-3030 Probably because the software that UNDP preferred only came from a U.S. vendor. Probably because the software that UNDP preferred only came from a U.S. vendor.

]]> By: Scott Caplan http://www.exportlawblog.com/archives/199/comment-page-1#comment-3029 Scott Caplan Tue, 24 Jul 2007 01:58:49 +0000 http://www.exportlawblog.com/archives/199#comment-3029 If they're not a U.S. person, why did they bother to apply for a license in 1999? Was it only available as U.S. origin back then? If they’re not a U.S. person, why did they bother to apply for a license in 1999? Was it only available as U.S. origin back then?

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