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Export Licensing - under Chemical& Biological...

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EXPORT LICENSING The Q-drum would only require a general export license, declaring the product type, destination, and value in order to export the product from the United State to either Rwanda or Tunisia. The product, made from linear Low Density Polyethylene does not fall under the ECCN’s Category 1 which contains all materials, chemicals, microorganisms, and Toxins. Under section 1C0101.a in the Commerce Control List the material polyethylene is not controlled in exports (1), designating the Q-drum as EAR99. EAR99 are items that “generally consist of low-technology consumer goods and do not require a license in many situations” (2). The only cases where you would need a license in exporting to both Tunisia and Rwanda on products that falls under EAR99 would be in cases where there is an embargo on the country or if the end use or end user of the product is of concern. The only restraints when exporting to Tunisia from the United State are on items that fall
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Unformatted text preview: under Chemical & Biological Weapons (CB1&2), Nuclear Nonproliferation (NP1), National Security, Missile Tech, Regional Stability, and Crime Control (CC1 &3). The exact same restrictions apply to Rwanda, however, under Crime Control, CC1, 2, & 3 apply, rather than just 1 & 3 for Tunisia. Rwanda does have some sanctions placed on it by the United Nations Security Council that fall within the scope of the UNSC’s arms embargo. All items under this embargo “apply to the sale or supply of arms and related material” (1). The Q-drum is a low-technology consumer good, made of a material that does not require a license and is exported to countries that do not have embargos or other licensing restricts. The end use of the product is to transport and easily store water in rural locations so there are no end use or end user regulations. Page 15: U.S Department of Commerce, Bureau of Industry and Security Export Administration Regulations Database...
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