Kristen Lane from Richardson Electronics and I were on a panel together at the recent ACI EAR Boot Camp in Chicago. Kristen had a great compliance tip that she implemented at Richardson which I asked her to write up so that I could pass it on because I thought it was a great idea. Here is what she sent me in an email:

I have put in place a process both at Richardson and a number of my clients through my consulting business (Lane International Trade Consulting) where they review every packing list that comes through their Receiving Department. This process can be setup a number of ways. To follow is an easily understandable way to implement using internal resources that may have some time to assist the business. The Receiving Department receives packages all day long. At the end of each day they gather the packing lists and give them to the Receptionist in the morning. The Receptionist reviews each packing list looking for any ECCN information or ITAR designation for which he/she has received special training from Trade Compliance. Any packing list with ECCN or ITAR information he/she will look up that item in the system and if the ECCN or ITAR information is different than what is on the system he/she will forward that packing list to Trade Compliance for review.

Trade Compliance then takes a couple of actions. For distributed items they look at the ECCN or ITAR designation to ensure it is correct and add it to the item master and look for any additional issues for any past sales, pending sales or future sales. For inbound materials used in manufacturing they will look to ensure there are no compliance issues for the end product being manufactured. Example, if ITAR component, end item will be ITAR; do they seek a different component that is not ITAR, etc. etc.

Not every company puts this information on their Packing Lists but the companies with good Trade Compliance programs do. I would say we get the export ECCN information on about 10% of our packing lists but if a company is also looking for HTS and Country of Origin information I would say we find that on about 30-40% of packing lists.

I have also noticed that these same companies that put the information on the packing lists also put it on their AP invoices.

We at Richardson do also add this information on our outbound packing lists and invoices so it lessens the chance that one of our customers can say to BIS or anyone else that they were not notified. Especially on our ITAR items that are sold and shipped within the USA.

This seems to me to be a procedure that can be easily implemented and can assist with the perplexing problem of classifying products from third parties that you might wind up exporting separately or as part of component or system that your company manufactures. Obviously, you should know the classification of your own products, but this procedure will flag other items that you might not realize is export controlled.

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