Advisory Opinions

BIS has selected certain advisory opinions that may be of general interest to the public. BIS will add future advisory opinions to this list as appropriate. Some of these advisory opinions have been redacted to avoid releasing identifying information that is protected under Section 12(c) of the Export Administration Act.

Date	Issue Examined
09/25/23	Export guidance and BIS interpretation of “gene” related to ECCN 1C353
06/09/23	Additional deemed export authorization not required for release of licensed technology and software to permanent and regular employees (as defined in 734.20(d)(2)) in the United States.
05/03/23	Non-proprietary system description shared in standards development
08/19/19	General Advisory Opinion Concerning Prohibited Activities in the Standards Setting or Development Context When a Listed Entity Is Involved
11/24/14	Cloud-based Storefronts
03/25/14	Scope of the General Technology Note
12/13/13	Application of “specially designed” to multipurpose die, standard packages, and integrated circuits comprised thereof
10/24/13	Time-Limited EAR99 Software on a Public Website
10/31/13	Deemed Reexport Guidance
08/05/13	Artwork to Cuba
02/21/13	Application of ECCNs 9A00l .a and 9A003.a to Aero Auxiliary Power Units (APUs)
02/23/13	EAR licensing requirements for deemed reexports to third-country national and certain dual nation
01/18/13	Interpretation of the Note to ECCN 9A001.a
10/25/11	Guidance for Preparing Commodity Classification (“CCATS”) Requests for Information Pertaining to the Development or Production of Carbon Fiber Organic Matrix Composite Items
01/11/11	Cloud Computing and Deemed Exports
12/27/10	Advisory Opinion Regarding Technology for the Development or Production of Carbon Fiber/Organic Resin Items
09/14/09	Second Incorporation Rule
09/11/09	Downloads of encrypted software reviewed and classified as "-mass market-"
07/01/09	Interpretation of ECCN 1A007: This interpretation has been superseded by the December 11, 2009 publication of a rule that removed the license requirement note in 1A007
02/10/09	Transfers of Licenses
01/13/09	Application of EAR to Grid and Cloud Computing Services
01/12/09	Software or technology related to Avionics Displays that employ techniques used to make two dimensional (2D) image appear as a three dimensional (3D)
11/10/08	Licensing Requirement Note to ECCN 2B350
10/14/08	Classification of computer preloaded with TSU-eligible encryption software
03/21/08	Clarifications on current technical parameters under ECCN 1C210: ECCN 1C210 Content Thermoset Resin
03/21/08	Clarification on current technical parameter under ECCN 3A233
11/19/07	Condition on permanent employees access to controlled technology/technical data (Note: this guidance supersedes that provided by BIS in agency interpretation dated 2/24/06)
09/13/07	Reminder of Wassenaar Arrangement's Munitions List Controls
08/02/07	Application of the Foreign Direct Product Rule to Exports of Encryption Technology
06/05/06	Exports and Reexports to Non-U.S. Embassies Located in Third Countries
07/19/06	License Exception Contradictions
05/04/06	Bullet-proof windshield glass
01/11/06	Nexus between export and deemed export requirements under the EAR and the foreign filing requirements under the USPTO regulations.
12/06/04	Public sale of US equipment to a foreign national and the "deemed export" rule
08/26/04	Involvement of a US-person in a foreign company
05/27/04	Availability of License Exception RPL
05/24/04	Classification of an item incorporated into a larger system
12/01/03	Foreign distributor as a "-sales representative-" under License Exception TMP
10/03/03	Availability of License Exceptions APR and RPL for foreign made products
07/14/03	Reexports to Iran
05/15/03	Clarification of ECCN 5E001.b.3
05/06/03	Remotely sensed imagery

(03/20/2024): Commerce Rule Advances U.S. National Security by Enhancing Coordination Between Commerce Export Controls and Treasury Sanctions

(03/14/2024): Commerce Updates Rules To Further Restrict Exports To Nigaragua Due To Foreign Policy Concerns

(3/07/2024): Chinese National Residing in California Arrested for Theft of Artificial Intelligence-Related Trade Secrets from Google

(3/05/2024): Two Defendants Arrested for Conspiring to Illegally Export Weapons to South Sudan

(3/01/2024): Russian International Money Launderer Pleads Guilty to Illicitly Procuring Large Quantities of U.S.-Manufactured Dual-Use, Military Grade Microelectronics for Russian Entities

(03/20/2024): Commerce Rule Advances U.S. National Security by Enhancing Coordination Between Commerce Export Controls and Treasury Sanctions

(03/14/2024): Commerce Updates Rules To Further Restrict Exports To Nigaragua Due To Foreign Policy Concerns

(3/07/2024): Chinese National Residing in California Arrested for Theft of Artificial Intelligence-Related Trade Secrets from Google

(3/05/2024): Two Defendants Arrested for Conspiring to Illegally Export Weapons to South Sudan

(3/01/2024): Russian International Money Launderer Pleads Guilty to Illicitly Procuring Large Quantities of U.S.-Manufactured Dual-Use, Military Grade Microelectronics for Russian Entities

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