Webinar: Specially Designed: The Most Important Term in Export Controls
April 21 • 12:00 pm – 1:30 pm (CST)
NAITA has partnered with the Export Compliance Training Institute (ECTI) to bring ECTI’s comprehensive export compliance training to our members with a discount!
Use Code NAITAweb for 10% off Live Webinars. Please note that Power Packs and other bundles are not included.
TWO important things about “specially designed”…
First, it plays a major role in clarifying and altering U.S. export controls on many products and technologies.
Second, understanding it is not always simple. Fortunately, it is not impossible to understand and apply, especially with ECTI guiding you through the voluminous regulatory and rule-making language to show you what you need to know and understand. Join us – for newfound skill and confidence in using specially designed for YOUR export classifications.
It has been several years since the Departments of State and Commerce defined the term “specially designed” in the International Traffic in Arms Regulations and the Export Administration Regulations. In that time, the phrase has become ubiquitous in the U.S. Munitions List (nearly 300 uses) and the Commerce Control List (over 1,000), affecting classifications and export license requirements for a huge range of items.
A thorough understanding of these two words is essential for anyone determining export control classifications of hardware, software, technology, or defense services on the USML or the CCL. This webinar will help you get a handle on how these wordy and complex definitions impact your export control jurisdiction and classification decision-making, whether you are considering a USML category or an Export Control Classification Number (ECCN).
At first glance, it is easy to overlook how a seemingly simple phrase can have such a major impact on export control classifications for such a wide range of items including equipment, materials, and components. If you take a closer look, and perform a systematic analysis using specially designed, you may find significant changes, possibly to your benefit, in your ITAR and EAR export classifications.
Unfortunately, some of the advantages that specially designed may provide to your exports may be counterintuitive. Did you know that a part which was designed for a missile still may not be considered specially designed for that missile? In fact, that part and related technology could be classified as EAR99 and eligible for export No License Required to nearly all countries. This webinar will cover these important points, as well as:
- The meaning and importance of the specially designed “catch-all”
- How specially designed fits in to the ITAR and EAR orders of review
- The “catch and release” approach of specially designed
- The across-the-board exclusion of minor parts
- The exclusion based on the existence of similar, but not identical items
- The exclusions for items intended for use in both highly controlled and lesser controlled equipment
- Understanding when specially designed is used to decontrol items
- Plenty of examples from both the USML and the CCL (600 series and other ECCNs)
- Suggestions for how to go about reclassifying your products based on the definition
This webinar will include PowerPoint slides and live video and commentary from Scott Gearity, who brings nearly 20 years of consulting, training, and corporate export compliance program management experience to bear for his clients. Each registrant, even if unable to attend, will have access to the presentation, certificate of completion, speaker contact information for follow-up questions, and access to the webinar recording within 24 hours after the webinar airs. Webinar participants are invited to submit questions during the webinar and the final 30 minutes will be allotted to answering attendee questions.
Speaker Bio: Scott Gearity is President of ECTI, Inc, with substantial experience in military, dual-use, and commercial export controls. His clients have ranged in size from small start-ups to some of the world’s largest companies, with a particular focus on the information technology, telecommunications, networking, and software industries. Mr. Gearity joined ECTI from Microsoft Corporation, where he was based in Ireland and managed the company’s export compliance program for Europe, the Middle East, and Africa. He continues to advise many non-US companies affected by US export controls. Mr. Gearity holds a Bachelor of Arts degree in international studies and economics from American University. He is a licensed US customs broker.
REGISTER NOW with NAITA discount code NAITAweb for 10% off Live Webinars. Please note that Power Packs and other bundles are not included.
Companies considering participating should respond by completing this linked questionnaire. Please submit your completed questionnaire for consideration in this Virtual Trade Mission hosted by the Government of Victoria, Australia.