With the move of thousands of articles from the jurisdiction of the ITAR to the Export Administration Regulations (EAR) comes a great benefit to Australian companies- the ability to obtain re-export licenses from the U.S. government without the need to go through a U.S. affiliate, business partner or supplier. As soon as the legislative changes moving articles from the jurisdiction of the ITAR to the EAR are published for each Category, Australian companies can begin applying to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for re-export and retransfer permission for transitioned items.
The advantage of obtaining a license from the BIS for transitioned items is two-fold. First, the Australian company can apply to the BIS directly for a license and receive a direct response. Second, the lead times for BIS license applications for EAR controlled items are much shorter than obtaining an export approval from the DDTC for an ITAR controlled item. BIS’ assessment typically takes three to four weeks. In addition, all applications and responses from BIS are done on-line through a portal where all applications and supporting documentation is automatically saved. The application process can be tracked from submission of the application by the Australian applicant to the granting of the license by BIS. In other words, the applicant will be able to see where the license application stands at all times.
Australian companies may also use the on-line portal to request advice on an item’s Export Control Classification Number (ECCN) where they are unable to determine the ECCN themselves. This may be useful in instances where an item in inventory needs to be re-exported or re-transferred and the U.S. supplier is either no longer contactable, or is unable to provide an ECCN.
Australian companies wishing to make license applications or request ECCN classifications from the BIS will first need to open an on-line account granting them access to the SNAP-R portal. There is one account per ABN, however there can be an unlimited number of company staff with administrative rights to use the system. Information about registering for SNAP-R can be found at https://snapr.bis.doc.gov/snapr/
The SNAP-R system is relatively easy to use. There is an extensive FAQ section as well as a manual for how to use the system. Australian companies may notice that the system is still geared for domestic companies in the U.S. (for example the phone number field will only accept the U.S format) but it is anticipated that the system will evolve to be more international over the coming months. For questions about using SNAP-R, Australian companies can contact the SNAP-R help desk; snapr@bis.doc.gov or phone at (202) 482-2227 (in Washington D.C.)
If you have further questions about registering for SNAP-R or using SNAP-R to obtain re-export permission from the BIS, please do not hesitate to contact Eva Galfi on 0421 506 095.
With the move of thousands of articles from the jurisdiction of the ITAR to the Export Administration Regulations (EAR) comes a great benefit to Australian companies- the ability to obtain re-export licenses from the U.S. government without the need to go through a U.S. affiliate, business partner or supplier. As soon as the legislative changes moving articles from the jurisdiction of the ITAR to the EAR are published for each Category, Australian companies can begin applying to the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) for re-export and retransfer permission for transitioned items.
The advantage of obtaining a license from the BIS for transitioned items is two-fold. First, the Australian company can apply to the BIS directly for a license and receive a direct response. Second, the lead times for BIS license applications for EAR controlled items are much shorter than obtaining an export approval from the DDTC for an ITAR controlled item. BIS’ assessment typically takes three to four weeks. In addition, all applications and responses from BIS are done on-line through a portal where all applications and supporting documentation is automatically saved. The application process can be tracked from submission of the application by the Australian applicant to the granting of the license by BIS. In other words, the applicant will be able to see where the license application stands at all times.
Australian companies may also use the on-line portal to request advice on an item’s Export Control Classification Number (ECCN) where they are unable to determine the ECCN themselves. This may be useful in instances where an item in inventory needs to be re-exported or re-transferred and the U.S. supplier is either no longer contactable, or is unable to provide an ECCN.
Australian companies wishing to make license applications or request ECCN classifications from the BIS will first need to open an on-line account granting them access to the SNAP-R portal. There is one account per ABN, however there can be an unlimited number of company staff with administrative rights to use the system. Information about registering for SNAP-R can be found at https://snapr.bis.doc.gov/snapr/
The SNAP-R system is relatively easy to use. There is an extensive FAQ section as well as a manual for how to use the system. Australian companies may notice that the system is still geared for domestic companies in the U.S. (for example the phone number field will only accept the U.S format) but it is anticipated that the system will evolve to be more international over the coming months. For questions about using SNAP-R, Australian companies can contact the SNAP-R help desk; snapr@bis.doc.gov or phone at (202) 482-2227 (in Washington D.C.)
If you have further questions about registering for SNAP-R or using SNAP-R to obtain re-export permission from the BIS, please do not hesitate to contact Eva Galfi on 0421 506 095.