An article from DLA Piper on 25 August says that many non-US-manufactured products are still trapped under the jurisdiction of the Export Administration Regulations (EAR). Whether or not foreign-made products incorporating US-origin content or manufactured from US-origin technology, machines or plants is now a primary consideration for major international technology and telecommunications companies because of the expansion of export prohibitions over the last decade. The article examines how a non-US-made product, but incorporating US-origin components or technology, can escape the technical jurisdiction of the EAR. It looks at the exceptions, including the de minimis rule, what is “incorporated” and what is not and is “controlled”.
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