Export Compliance Overview
Many of the products sold by PTB Sales are considered “Dual Use” (Commercial Application and Military Use). As a result, PTB Sales is governed by 2 sets of Regulations – Department of State (ITAR) and Department of Commerce (EAR). It is the responsibility of PTB Sales as an Exporter to ensure proper classification of controlled goods and to “Know its Customers” per Department of Commerce guidelines in Supplement 3 to Part 732 of the EAR.
- Under no circumstances, will PTB Sales sell products contrary to U.S. Export regulations and laws.
- All parties to U.S. Export transactions must ensure their exports fully comply with all statutory and regulatory requirements.
- Compliance not only involves controlled goods and technologies, but also restrictions on shipping to certain countries, companies, organizations, and/or individuals
- Hiring an agent, whether a freight forwarder or some other agent, to perform various export tasks, does not relieve PTB Sales of its compliance responsibilities.
- PTB Sales must adhere to ITAR notifications by Customers.
- Under the “Know your Customers” guidelines, we must understand:
- What is the product you are purchasing?
- What is the final destination of the product?
- Who is the ultimate end user?
- What is the end use?
- If required, PTB Sales must have all approvals in place before export of product or Technical Data.
- If ECCN is requested from a customer and/or distributor, please send a completed BIS-711 form to PTB Sales.
WHO WILL BE REQUIRED TO COMPLETE A BIS-711 FORM?
- All Customers with Foreign “Ship-To” addresses.
- Those Domestic customers we know or believe will export our product.
- Information on Form is cross-checked with “Consolidated Screening List” that is accessed via the BIS web site to validate customer/end-user is not:
- In a Restricted Country (i.e. on the Nonproliferation Sanction list);
- On the Denied list;
- On Debarred List (i.e. not allowed to order defense articles);
- On the Specially Designated Nationals List
- If there are questions related to information contained on the BIS-711 we will be consulted for feedback.