End User Certificate - PowerPoint by gbp12616


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									        July 6, 2006
Proposed “China Catch-all rule”
    China “Catch all” regulation
• Rule that would add license requirements (for
  things that do not normally require a license)
  when you there is knowledge that an export or
  reexport is intended for military end-use in the
• Items affected are listed in a supplement and are
  basically AT controlled items identified by xx992,
  xx91, etc. (Supplement 2 to Part 744)
               US Persons
• EAR 744.6 extends the scope of the
  requirements for licenses for transfers of
  NLR items to PRC military end-uses to
  include “US person” involvement in such
  activities, even when the items being
  transferred are not subject to US
  jurisdiction. This provision says that if you
  are a “US person,” you may not support a
  transfer described in the new 744.21
  without a license.
     PRC End-user certificate
• PRC End-User Certificate required from
  the Ministry of Commerce of the PRC for
  license applications if the items in any
  single ECCN are valued at over $5,000.
• Exporter must keep on file for 5 years and
  include certificate number on license
        Validated End-Users
• A license is not required for certain exports
  to a Validated End-User (VEU) in the
• EAR 748.15: If the US Government puts a
  PRC entity on the Validated End-User list
  in Supplement 7 to Part 748, you would be
  able to export and reexport most items
  without a license to the VEU entity.
• Foreign availability
• Costs of screening end-users
• Clarity of “military end-use” definition
• VEU program
• Application of new controls to other
  ECCNs (e.g., 5D002)?
• End-user certificates
• Consultation with other countries

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