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ARTICLE · 10 JUNE 2021

Navigating The Export Controls On Semiconductors

Braumiller Group (Dallas)
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Determining what export controls apply to semiconductor devices can be a challenging task.

United StatesInternational Law
Bruce H. Leeds
Bruce H. Leeds
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Determining what export controls apply to semiconductor devices can be a challenging task.  Most controls on semiconductor devices are found in Export Commodity Classification Number (ECCN) 3A001 of the Commerce Control List (CCL) in the Export Administration Regulations (EAR).  That ECCN has nearly 16 pages of detailed controls on many types of semiconductors.  Classifying articles in that category and determining what licenses or exceptions may apply is not easy.

First things first: Make sure the semiconductors to be exported are not subject to the International Traffic in Arms Regulations (ITAR).  If the devices will be used in a military or space application, they may be subject to ITAR controls.  Better read the fine print in the US Munitions List to find out.

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