Q4 2017 ATI Surcharges Published

Q3 2017 ATI Surcharges Published

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FAQ: Exporting Titanium Products from the United States

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…]

Q2 2017 ATI Surcharges Published

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Q1 2017 ATI Surcharges Published

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Q4 2016 ATI Surcharges Published

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Q3 2016 ATI Surcharges Published

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Q2 2016 ATI Surcharges Published

Q1 2016 ATI Surcharges Published

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AS6279 – What You Need to Know

On October 15, 2015, a new specification called AS6279, “Standard Practice for Production, Distribution, and Procurement of Metal Stock” went into effect. AS6279 adds several new responsibilities related to chain of custody, traceability, certifications, record retention, product substitutions, and dimensional limits.

If you supply or purchase materials to specifications such as AMS 4900, AMS 4901, AMS 4911, AMS 4919, AMS 4928, AMS 4930, AMS 4965, AMS 4967, AMS 4971, AMS 4978, AMS 6930, AMS 6931, AMS 6932, AMS 6936, you are affected. Additional specifications will begin to incorporate AS6279 as they are revised.

AS9100/AS9120 Certification: Perhaps the most significant requirement is that producers and distributors of titanium being sold to the above specifications, must be accredited to AS9100 or AS9120, unless otherwise approved by the cognizant engineering organization.

Definition of “Producer”: AS6279 establishes that any organization can become a “Producer” by coordinating manufacturing operations, even if that organization does not perform any processes in-house. An organization authorizing processes that change material gauge, condition, or specification, is a Producer. Producers are responsible for ensuring that material meets all specification requirements for the new dimension, condition, or specification. Producers are required to identify themselves and provide information about manufactured products to MMPDS (Metallic Materials Properties Development and Standardization), which is used to analyze design allowables for aerospace structural designs.

Product Substitutions: It is not appropriate to substitute product forms without authorization from the cognizant engineering organization. Plate and flat bar may look similar, but the inherent product characteristics are different. Organizations must also ensure the thickness or Short Transverse dimension is not cut to achieve desired thickness, without authorization from the cognizant engineering organization.

Chemical Milling: Chemical milling or pickling shall only be used for alpha case removal or pre-penetrant etch, unless approved by cognizant engineering organization.

Ordering Information: Aside from standard ordering information, purchasers must ensure that any relevant requirements are flowed down from the cognizant engineering organization. Include requirements for grain direction, as well as maximum allowable gauge. When the size being ordered exceeds the range covered by the AMS specification, purchasers must flow down any mechanical property requirements or supplemental tests that must be satisfied.

Free introductory training presentations are available at: http://www.sae.org/servlets/works/committeeHome.do?comtID=TEAAMSMGC

AS6279 is available for purchase through SAE International: http://standards.sae.org/as6279/