Effective October 1, 2016, the Department of Commerce, Bureau of Industry and Security (BIS) will remove the license type C32, No License Required (NLR), from the list of License Types in the Automated Export System (AES). As a result of this action, C33 will be the only License Type in AES designating a NLR shipment.
With this change, United States Principal Parties in Interest (USPPIs) and their authorized filing agents (AES filers) must adhere to the Export Control Classification Number (ECCN) reporting requirements for NLR designated shipments under License Type C33 as per the Export Administration Regulations (EAR) 758. 1(g)(3), which states: “you must enter the correct ECCN on any required EEI filing for all items being exported under the NLR provisions that have a reason for control other than or in addition to antiterrorism (AT).
Changes to License Type C32 designated Electronic Export Information (EEI) will be accepted in AES for 180 days (6 months) after the effective date. For items that have a reason for control other than or in addition to Anti-Terrorism (AT), report No License Required (C33) as the license type in the EEI filing.
This change is being made as a result of several requests from industry to simplify the NLR reporting in AES. The change also reduces the confusion associated with having two NLR license types in AES.
A complete list of all of the AES License Type codes and reporting instructions for these types can be found here.
For questions regarding these AES changes, please contact the Bureau of Industry and Security (BIS) by email at ECR_AES@bis.doc.gov or at (202) 482-4933.
For general questions regarding AES, please contact the International Trade Management Division at the Bureau of the Census at 1-800-549-0595, option 1.
For classification questions about ECCNs, please contact the Bureau of Industry and Security at one of the numbers below:
- Outreach and Educational Services Division (located in Washington, DC) (202) 482-4811
- Western Regional Office (located in Irvine, CA) (949) 660–0144
- Northern California branch (located in San Jose, CA) (408) 998-8806
Your general questions regarding this Regulatory update can be directed to Livingston’s US Regulatory Affairs group: usregaffairs@livingstonintl.com.