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For everyone who has been complaining that export controls imposed by the Bureau of Industry and Security (“BIS”) have meant that U.S. manufacturers aren’t on a level playing field with foreign competitors, it’s now time to put your money, or at least your comments, where your mouth is. BIS has just solicited comments from the export community on whether “U.S. export controls influence manufacturers’ decisions to use or not use U.S.-origin parts and components in commercial products and the effects of such decisions.
Specifically, BIS is interested in whether export controls, such as licensing requirements for for foreign-manufactured goods with more than de minimis U.S. content, have an actual economic impact on U.S. manufacturers and exporters. The agency is soliciting not only specific and quantitative data but also “anecdotal information.”
Areas of interest to BIS include:
- Information about advertising campaigns by foreign competitors touting the absence of U.S. content in their products
- Information about customer preferences for products without U.S. content
- Examples of lost sales to foreign competitors because of a preference for goods without U.S. content
- Examples of items re-engineered to exclude U.S. content because of U.S. export controls
- Examples of relocation of manufacturing facilities to avoid U.S. export controls
Comments are due by February 19, 2009, and may be submitted via e-mail to [email protected]. The subject line must reference ‘‘Parts and Components Inquiry.” For those who wish to send comments by snail mail, the address can be found in the public notice.
So speak by February 19 or forever hold your peace.
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Copyright © 2009 Clif Burns. All Rights Reserved.
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