According to settlement documents released by the Bureau of Industry and Security (“BIS”), New Jersey based Phibrochem agreed to pay $31,000 to settle charges that it exported $14,000 worth of sodium fluoride to Mexico without a license. Sodium fluoride, which is classified as ECCN 1C350, can be used to produce methylphosphonyl difluoride which, in turn, is used to produce the nerve gas sarin.

The first reaction you might have to this case is to wonder whether Phibrochem was even aware of the license requirement. After all, sodium fluoride is everywhere. It’s in tap water for Pete’s sake. The charging documents, however, make clear that this wasn’t an innocent mistake by noting that Phibrochem had previously obtained a license to ship sodium fluoride to the same end user in Mexico.

And your next thought may well be, forget TSA requirements, do I need a license to take a tube of Crest on my next trip to Europe? Do I have to buy some strange brand of toothpaste called Odol-med3 in Berlin to avoid being arrested when I board my flight at Dulles? Thanks to note 2.b, your Crest is safe:

A license is not required under this ECCN for a mixture, when the controlled chemical in the mixture is a normal ingredient in consumer goods packaged for retail sale for personal use.

Whew.

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Copyright © 2012 Clif Burns. All Rights Reserved.
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