BIS Issues Guidance on Carbon Fiber Organic Matrix Composite Item Classification Requests

December 20, 2011 by Marie Rapport|Exports, OFAC and DoD

The Bureau of Industry and Security has posted an "advisory opinion" guidance document for the public to use when preparing commodity classification (“CCATS”) requests for information pertaining to the development or production of carbon fiber organic matrix composite items. BIS states that it hopes to begin building a public collection of carbon fiber organic matrix composite-related classification determinations that will be the foundation for common understandings between industry and government.

The 14-page guidance document is divided into five sections:

Background - Classification Requests (formal determinations, etc.)
Purpose of Document (building a public collection of classification determinations, etc.)
Background - EAR Provisions Pertaining to Composite Technology (rules for determining when the export of technology is and is not "required" for purposes of ECCN 1E001, etc.)
Factors to Consider and Address when Drafting Composite Technology- Related Classification Requests (technology for the development or production of 1C010.e materials, 1C210 materials for 1C010.b fibers, etc.)
Conclusion (guidance limited to the EAR in effect at the time of publication; exporters still need to refer to the EAR to determine export control obligations pertaining to any particular export; questions can be referred to (202) 482-4811; etc.)

(10/25/11 posting date)