License Requirements
A license is required to export or reexport all items subject to the Export Administration Regulations (EAR) to Syria of other than food or medicine designated as EAR99, as described in Section 746.9 of the EAR.
License Exceptions
A license exception is a general authorization to export or reexport items without a license under stated conditions. Only the license exceptions, or portions thereof, listed in Section 746.9 of the EAR are available for Syria. You may export or reexport to Syria without an individual validated license if your transaction meets all the applicable terms and conditions of the available license exceptions. To determine the scope and eligibility requirements, you must review the sections or specific paragraphs of Part 740 of the EAR. Read each license exception carefully, as the provisions available for sanctioned countries are generally narrow.
Licensing Policy
There is a general policy of denial for exports and reexports to Syria of items subject to the EAR. However, BIS may review several categories of items on a case-by-case basis, including:
- Medicine on the Commerce Control List (CCL) and medical devices;
- Telecommunications equipment and associated computers, software, and technology; and
- Parts and components intended to ensure the safety of civil aviation and the safe operation of commercial passenger aircraft.
Item-specific Guidance
Food
For the purpose of exports and reexports to Syria, food is defined in Section 772 of the EAR as items that are consumed by and provide nutrition to humans and animals, and seeds, with the exception of castor bean seeds, that germinate into items that will be consumed by and provide nutrition to humans and animals. Examples of "food" include, but are not limited to, processed or unprocessed food items for human consumption, feed, livestock, vitamins, minerals, food additives, dietary supplements and bottled water. Food does not include cigarettes, alcoholic beverages, or gum.
As noted above, EAR99 food does not require a license for export or reexport to Syria.
Medicine and Medical Devices
A license is not required to export or reexport to Syria medicine designated as EAR99. However, a license is required to export or reexport to Syria medicine on the CCL, such as certain vaccines and immunotoxins, and medical devices that are subject to the EAR. Such applications are reviewed on a case-by-case basis when the items will be for the benefit of the people of Syria. This does not extend to applications in support of general research or in support of the Syrian pharmaceutical industry.
For purposes of the EAR, medicines include prescription and over-the-counter medicines for humans and animals. Medical devices include medical supplies, instruments, equipment, equipped ambulances, institutional washing machines for sterilization, and vehicles with medical testing equipment. Note that License Exception Servicing and Replacement of Parts and Equipment (RPL) is not available for Syria. Therefore, an individual validated license is required to export or reexport to Syria replacement parts and components that are subject to the EAR, including for use in medical devices.
Other U.S. Government Agencies
Please be aware that other U.S. Government agencies administer regulations that could also impact your export or reexport transaction. For example, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains certain Syria-related sanctions. Exporters and reexporters are responsible for complying with all applicable regulatory requirements.
Questions
For questions specific to Syria, contact the Foreign Policy Division at 202-482-4252.