We get a lot of questions about exporting titanium products such as titanium bar, sheet, and plates from the United States to a foreign country. It’s no simple process, and it’s easy to slip into a violation of U.S. export control regulations. Today, we’re doing a Q&A with Emmalie Armstrong from Export Solutions, Inc., to help educate us on the “do’s and dont’s” of exporting titanium.
PTG: What’s the reason for the Export Administration Regulations (EAR)?
Emmalie Armstrong: The EAR regulates the export of dual-use items. These regulations are implemented by the Bureau of Industry and Security (BIS) under the U.S. Department of Commerce. The regulations exist for three main reasons: national security, as an element of foreign policy and also to control the spread of nuclear proliferation and weapons of mass destruction. By having these regulations in place, the risk of diverting certain items to locations that are not in the best interest of the United States is minimized, and U.S. technology is protected.
PTG: Any time a titanium product is exported from the U.S., it’s important for the “USPPI” (U.S. Principal Party in Interest) to gather information about the purchaser, the final end user of the titanium, and the end use application of the titanium. Can you tell us why?
Emmalie Armstrong: U.S. export regulations are far-reaching. Once a controlled item leaves the United States, the responsibility doesn’t end there. The controls follow that item around the globe. Knowing the end-user is a key part of export compliance. As the exporter (or USPPI), you are responsible to know the item’s ultimate destination and end-use to ensure that the shipment is complying with export regulations, and that the item is not destined for a prohibited location or end-use.
PTG: OK, so once the USPPI has obtained the names and addresses of all of the parties related to the transaction, including the consignee, the end user, the freight forwarder, and any brokers, that information must be checked against the U.S. Government’s Restricted Parties Lists. How does Export Solutions do this?
Emmalie Armstrong: There are lots of tools to accomplish this. The U.S. government publishes lists of countries, companies, and individuals throughout the world who are not allowed to participate in the export of restricted items, and in some cases, any items at all. These entities are collectively referred to as “restricted parties.” Companies need to be aware of who they do business with in order to avoid violations. At Export Solutions, we use a restricted party screening tool. There are many vendors on the market who provide these tools. However, the lists can also be found free of charge at: http://2016.export.gov/ecr/eg_main_023148.asp. The key is to make sure that your item is not destined to an entity, person, or country that is restricted. Using a tool reduces the amount of time spent searching through the multiple lists that exist throughout different agencies. [Read more…]