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BIS License Exceptions

There are several general BIS license exceptions that may be used in lieu of obtaining a license. To use an exception, none of the 10 restrictions that are applicable to all BIS license exceptions must be present (EAR §740.2). These include many items controlled because they are missile technology controlled items and goods being exported to certain countries, among others.

One commonly used exception is Strategic Trade Authorization (STA). STA allows specific controlled goods to be exported to certain countries deemed low-risk without a license. For 600 series goods, the ultimate end-user must be the government of one of the 36 countries or the U.S. and no major defense equipment valued over $25 million may be exported using this exception.

Another commonly used exception is Servicing and Replacing of Parts (RPL). RPL authorizes export for “one-for one replacement of parts, components, accessories, and attachments” (EAR §740.10). Among the restrictions on the use of the exception includes not holding any spares in an inventory and that all original parts must have been exported legally.

Lastly, Temporary Imports, Exports, Re-exports, and Transfers (TMP) allows goods to leave the country for less than one year for reasons such as export of tools of trade involved in repair, to attend a trade show, or items moving in transit through the United States.

For all exceptions, it is important to read EAR §740 to make sure the situation falls within the parameter and is not disqualified by one of the restrictions.

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