Author: Reynaldo Roman | Senior Director, Regulatory Compliance

As of June 29, 2020, exporters of shipments to China, Russia, or Venezuela must comply with a new, mandatory export filing requirement.

Any export shipment from the United States to China, Russia, or Venezuela, involving an item classified under an Export Control Classification Number (ECCN), requires an export filing via the Automated Export System (AES) regardless of value.

This new rule does not mean that all shipments destined to China, Russia, or Venezuela require an export filing. The Bureau of Industry and Security’s FAQ, published on April 28¹, clarifies that the rule applies only to the export of items classified under an ECCN listed on the Commerce Control List (CCL). As an example, EAR99 items destined for any of these countries are not subject to the new filing requirement.

US exporters must exercise due diligence to determine if their export items are classified under an ECCN and, if so, comply with the new filing requirement when sending shipments to China, Russia, or Venezuela.

Questions about the new mandatory filing requirements can be sent to tradecompliance@marken.com

¹ https://www.bis.doc.gov/index.php/documents/pdfs/2566-2020-meu-faq/file