This Guidance does not create any privileges, benefits, or rights, substantive or procedural, enforceable by any individual, organization, party, or witness in any administrative, civil, or criminal matter.



The applicability of de minimis is not end-user/use based. It is destination based. Therefore, the items that are subject to license requirements under §746.5 of the EAR should not be included as controlled content in calculating the de minimis percentage of an item proposed for re-export to Russia.

© BIS 2020